The Australian Transaction Reports and Analysis Centre (AUSTRAC) has finalised its enforceable undertaking with National Australia Bank (NAB) after the bank satisfied its obligations under the agreement. The enforceable undertaking, accepted in April 2022, covered NAB and four NAB-related companies and was designed to address shortcomings in compliance with Australia’s anti-money laundering and counter-terrorism financing (AML/CTF) laws, including customer identification procedures, ongoing customer due diligence, and the adoption and maintenance of a compliant AML/CTF program. An independent external auditor found NAB had met the terms of the undertaking, and also made recommendations outside its scope to further enhance the bank’s AML/CTF program, including transaction monitoring and assurance frameworks, which NAB has accepted. AUSTRAC said finalisation does not amount to a “clean bill of health” and expects NAB to continue strengthening interconnected elements of its AML/CTF controls.