Author: Viktor H
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When the Audit Passes and the Problem Doesn’t: The Airwallex AUSTRAC Story

By Viktor Ha | April 2026 | AML-CAMS Blog Airwallex had already been audited. AUSTRAC looked at their program in 2024. An independent external reviewer followed up in 2025 and signed off — controls in place, systems adequate, no major concerns. Then, on 22 January 2026, AUSTRAC ordered another external audit. This time under section… Read more
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You Can Outsource the Work. You Can’t Outsource the Obligation.
AUSTRAC has filed its first-ever civil penalty proceedings against a registered licensed club. Not a casino. Not a bank. A community club in Sydney’s west with 1,400 poker machines and $4.17 billion in customer deposits over four years. Mount Pritchard District and Community Club — better known as Mounties — is one of the largest… Read more
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If It Can Get a Home Loan, It Can Pass Your CDD — AI Document Fraud & AML Risk
Commonwealth Bank invested $900 million in fraud protections last financial year. It still ended up with a suspected $1 billion problem in its loan book. The bank self-referred to police and ASIC after uncovering potentially doctored home loan applications — including documents generated by artificial intelligence. It followed an earlier alleged fraud at NAB, and… Read more
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31 March 2026: What’s Transitional, What’s Not, and Why the Distinction Will Catch People Out
The three-year grace period for initial CDD made headlines across the Australian compliance community. What didn’t make headlines is everything that has no grace period at all. On 31 March 2026 — now just weeks away — Australia’s reformed AML/CTF Act takes effect for existing reporting entities. The transitional rules announced by AUSTRAC and the… Read more
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Swedbank’s Fresh AML Probe: What Happens When Remediation Doesn’t Stick
By Viktor Ha | February 2026 | AML-CAMS Blog A record SEK 4 billion fine. An internal investigation spanning 12 years. Remediation programs across four countries. A former CEO prosecuted. And on 20 February 2026 — just last week — Sweden’s Financial Supervisory Authority (Finansinspektionen, or FI) announced it will investigate whether Swedbank’s customer due… Read more
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Bendigo Bank’s $50M Capital Add-On: Analyzing the APRA & AUSTRAC Joint Enforcement
By Viktor Ha | February 2026 | AML-CAMS Blog When APRA and AUSTRAC jointly announced enforcement action against Bendigo and Adelaide Bank on 17 December 2025, the headline number was AUD 50 million — an operational risk capital add-on that landed effective 1 January 2026. But the number is not the story. The story is… Read more





