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CriticalBanking20 November 2020

Westpac AML Monitoring Missed 23M+ Transactions — $1.3B Penalty

Westpac Banking Corporation

What happened

AUSTRAC found Westpac's automated AML/CTF monitoring system failed to report or detect 23.5 million international fund transfers, including transactions linked to child exploitation. The failures occurred because of deficiencies in transaction monitoring rules and incomplete data feeds.

Root cause

Automated compliance monitoring with inadequate coverage of international payment channels; monitoring rules not updated as payment products changed; no drift detection on transaction monitoring coverage rates.

Architectural failure

Transaction monitoring system's data ingestion scope was never validated against the full set of payment rails; alert suppression rules masked systemic gaps; no model performance monitoring.

Outcome

$1.3B civil penalty — the largest in Australian corporate history at the time. AUSTRAC found 23M+ contraventions. CEO and Chairman resigned.

Architectural Failure Patterns

These pattern categories on aipatterns.com.au describe the systemic failure modes this incident exhibited.

Cite this incident

https://corporateai.com.au/incidents/westpac-austrac-aml-2020