Anti-Money Laundering and Counter-Terrorism Financing

Criminals use financial institutions to conceal their illegitimate funds with the aim of making ‘dirty money’ clean, this is known as money laundering. Terrorism financing is the financial support of terrorism or of those who encourage, plan, or engage in terrorist activities.

As a division of the Commonwealth Bank Group, Bankwest complies with the Anti-Money Laundering (AML) / Counter-Terrorism Financing (CTF) Group Policy. Money laundering and terrorism financing (ML/TF) risk refers to the likelihood and impact of the Commonwealth Bank Group (the Group) being involved with or facilitating this unlawful activity.

The Group is committed to:

• meeting its international regulatory obligations in the identification, treatment and management of ML/TF risk
• protecting the Group from reputational risk and breaches of regulatory requirements that may lead to severe fines and penalties; and
• safeguarding the Group, its customers and employees from becoming a victim of, or unintentional accomplice to, ML/TF activities.

The Group is intent on satisfying its local regulatory and international obligations in a sustainable manner.

The Anti-Money Laundering and Counter-Terrorism Financing rules (AML/CTF) have been strengthened. To meet these obligations, Bankwest will be making changes to its systems and processes to ensure we can prevent our products and services from being used to hide the proceeds of crime or finance terrorism. These changes will mainly affect Companies, Trusts, Partnerships and Associations.

If you are a new customer you may need to provide extra information and documents proving your identity when you open a new account with us. We will also need to gather and verify information relating to any Beneficial Owners by virtue of ownership or control (Key Decision Makers). For Trusts we may need additional information relating to the Settlor, Trustees and Appointor. Certain information given may also need to be verified even if the individuals are not signatories on the account.

If you are an existing customer you may need to periodically confirm that the information we hold about you, including for any Beneficial Owners, Key Decision Makers and Trustees, is up to date. We may also need to contact you to update our records with any additional information we are now required to capture.

The Anti-Money Laundering (AML) / Counter-Terrorism Financing (CTF) Group Policy determines the principles that all CBA Group entities must adhere to in their identification, treatment and management of money laundering and terrorism financing risk. The Group must comply with the AML/CTF laws in a number of different countries in which it operates due to the geographic reach of its activities and operations. All Group entities are required to comply with the policy principles irrespective of their geographic location. Where the laws of a particular jurisdiction are of a higher standard, then the higher standard must be applied.

Our policy provides key principles that all the Group’s entities must adhere to in their identification, treatment and management of money laundering and terrorism financing risk.

1. The Group operates an AML/CTF Program that:
   • meets the requirements of the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (and associated laws)
   • is supported by policies and procedures to combat money laundering and terrorism financing
   • is monitored and tested to ensure policies and procedures remain effective and are adhered to.
2. The Group will identify and report suspicious behaviours by:
   
   • ensuring authorities receive the necessary information to further investigate any illegal activities
   • educating our employees so they can identify, monitor and report suspicious matters
   • ensuring our employees are aware that suspicious matters are not limited to financial transactions
   • submitting, when appropriate, suspicious matter reports to AUSTRAC (the Australian Transactions Report and Analysis Centre).
3. The Group will endeavour to protect itself from being used for illicit activities by:
   
   • conducting customer identification and verification processes to ensure our customers are who they say they are
     
   • only dealing with legitimate customers and ensuring our products and services are not being utilised by money launderers, terrorist financers or anybody that chooses to support these types of individuals
   • carrying out ongoing customer due diligence.
4. The Group will manage Employee Due Diligence by screening all prospective and existing employees, contractors and temporary employees.
5. The Group will retain all relevant records for seven years (or any other time period as required by law).
6. The Group’s AML/CTF training program will ensure employees receive relevant and ongoing training. The program will provide an awareness of money laundering and terrorist financing, indicate how to identify and report a suspicious matter and inform our employees of our regulatory obligations under the AML/CTF Act.

Our policy provides key principles that all the Group’s entities must adhere to in their identification.

• The Group Head of AML/CTF for CBA is designated the AML/CTF Compliance Officer
• All material documents that form part of the Program must be approved and adopted by the Executive Committee and by the Board of the Commonwealth Bank of Australia Limited
• The Group’s Risk Committee has ongoing oversight of the Program
• Each Group Executive is responsible for ongoing oversight of the Program as it affects their area of responsibility and for delivering effective compliance on a day to day basis.