The case brought by the Australian Transaction Reports and Analysis Centre against the Commonwealth Bank of Australia had its final day in Federal Court yesterday, after CBA agreed to a A$700 million fine. This will bring to a swift conclusion another long running and potentially damaging court case, given the amounts involved and the period over which the offences occurred.Austrac's lawyer took Justice David Yates through the statement of agreed facts and submissions, filed on 4 June 2018, noting that "the consequence of the breaches by CBA are very serious and the [$700 million] penalty reflects that breach of trust."He then went through the various specific breaches of the anti-money laundering and counterterrorism financing legislation and explained how each segment of the penalty was calculated. Justice Yates heard that both parties agreed the penalty was the appropriate outcome, and left it to the court to consider the detailed reasoning, which was summarised in its main components as; The failure to identify and mitigate the risk inherent in introducing intelligent deposit machines. The parties agreed this happened on 14 occasions and had agreed to look at the breaches separately and in total to arrive at a penalty of $180 million, not far short of the theoretical maximum that could be imposed of $238 million. Approximately 778,000 accounts were not monitored for contraventions. The penalty for failure to monitor transactions in relation to these accounts, which would have impeded Austrac and other regulators by depriving them of information, was agreed at $100 million. The approximately 53,500 late Threshold Transaction Reports, ie payments of $10,000 or more into CBA's intelligent deposit machines, which should have been filed on time over a period of three years. Most of these were only reviewed and lodged after Austrac drew the CBA's attention to them. Austrac said during this time around $625 million was put through the bank's IDMs, of which at least $17.5 million was money being laundered by customers who had been identified by the bank as high risk. For this the penalty was $125 million. The next set of contraventions was outlined related to the failure to lodge 149 suspicious matter reports to Austrac within the three business days required by the legislation. These failures occurred between August 2012 and July 2014. CBA did not submit SMRs either on time or at all. "The bank now accepts it had a legal obligation to do so," Austrac's lawyer noted. The agreed penalty for these contraventions was $125 million. CBA also has - as indeed do all ADIs - an obligation to monitor customers in order to mitigate AML and CTR risks. There were some 80 customers that CBA should have taken action against. For this failure, given the serious systemic nature of the offences, the bank agreed to a $170 million penalty. CBA also agreed to pay the costs of Austrac which were not disclosed to the court, but which were disclosed in a statement later that