The Commonwealth Bank yesterday announced via an ASX statement circulated after close of trade that is has filed its response to the civil proceedings commenced by Austrac on 3 August 2017.The CBA said it would be contesting several allegations - both in terms of the type of allegations and it quantum - while conceding that allegations relating to the late submission of 53,506 threshold transaction reports were correct. However, CBA was still running one strand of a previous argument, which holds that all were all caused by the same single systems-related error.  CBA said these 53,000-plus breaches were caused by the same systems-related error, and said this represents just 2.3 per cent of TTRs reported by CBA to Austrac between 2012 and 2015: "During the period of the claim, CBA submitted more than 36,000 SMRs, including 140 in relation to the syndicates and individuals referred to in AUSTRAC's claim," the bank's ASX statement explained."In the same period we submitted more than 17 million reports in aggregate, including SMRs, TTRs and in respect of international funds transfer instructions. CBA will submit over 4 million reports to Austrac in this year alone." The bank also disagreed on how the penalties were to be calculated, arguing that the risk assessment requirements for Intelligent Deposit Machines - but did not accept that this amounted to eight separate contraventions. Again, CBA agreed "we did not adhere to all our transaction monitoring requirements in relation to certain affected accounts"" but then indicated it will challenge almost as many suspicious matter reports as it accepts (admitting to 91 charges in whole or in part, but denying a further 83).The pattern is a similar one for allegations regarding customer due diligence requirements:  admitting 52 (in whole or in part) but denying a further 19 allegations.Later today (Thursday 14 December), Austrac is expected to file an amended statement of claim against CBA, with 100 additional alleged contraventions. In anticipation of this, CBA's statement to the ASX also noted: "If an amended claim is served on us, we expect the court would set a timetable for CBA to file an amended defence. We will provide market updates as appropriate.""Any penalty imposed by the Court as a result of the mistakes we have made will be determined in accordance with established penalty principles. For example, the Court may consider whether any contraventions arise out of the same course of conduct and will assess the appropriate penalty for that conduct accordingly, as it recently did in the Tabcorp decision." CBA said its submissions at trial would also highlight steps that it has taken since 2015 as part of a "Program of Action" to strengthen and improve financial crimes compliance. CBA rounded off its ASX announcement with the boilerplate that "[the bank] is committed to continuing to strengthen our financial crimes compliance and to working closely with regulators across all jurisdictions in which we operate to fight financial crime."Which is just as well, as APRA has been on the record that the investigation has