As was widely expected - indeed, it was foreshadowed by CBA itself - Australia's antimony laundering regulator Austrac served Commonwealth Bank with an amended statement of claim yesterday. In it, Austrac alleged 100 further contraventions of Australia's anti-money laundering and counter-terrorism financing legislation, taking the total number of alleged breaches to 53,800. In response, CBA updated the market via an ASX announcement, and added it would review the amended statement of claim and update the market as appropriate. "We will file an amended defence in due course," CBA said.CBA re-stated its position that "we take our anti-money laundering and counter-terrorism financing (AML/CTF) obligations extremely seriously, and deeply regret any failure on our part to comply with these obligations.""Risk management is fundamental to running a bank. It sits at the heart of everything a bank does. So this case stands as a pretty stark warning about the consequences for financial institutions that take a short-term view of building shareholder value, at the expense of basic risk management controls," according to Nathan Lynch, head of financial crime and risk, regulatory intelligence at Thomson Reuters. "The two alleged terrorism financing breaches are a significant escalation in this case for CBA. These are the most important issues to report under the AML/CTF regime and businesses have to file these with AUSTRAC within 24 hours. Law enforcement agencies need to get their hands on that information as soon as a bank or another institution identifies something suspicious," said Lynch."There are numerous cases where information from a vigilant bank has led to the interception of a terrorist act. So this financial intelligence is critical to allow law enforcement agencies to follow the money trail."The expansion of this claim "will ratchet up the pressure on CBA to settle. It's highly likely that both parties are already in discussions about the appropriate penalty and any other remedies the bank might have to undertake," Lynch said. "CBA has already admitted to the vast majority of the breaches, so there would be little to be gained for either side by taking this to trial," Lynch said."In the bigger picture, Austrac has a good working relationship with CBA that it wants to continue. So the long-term benefits are there for both parties if they can resolve this. Really, it all depends upon CBA's willingness to rebuild its management culture and to commit to preventing these types of failures from ever happening again."The bank said that the Group commenced a program of action in 2015 to significantly upgrade and expand its operations to ensure compliance with the AML/CTF Act. "During 2017 we have stepped up the rigour and intensity of the program and extended it across all aspects of financial crime obligations and all business units to further strengthen regulatory compliance," CBA said.CBA asserted it has made "significant progress" in strengthening its policies, systems and processes relating to its obligations under the AML/CTF Act, adding that it  "recognises that having increased the scope of work and resources being deployed we may come across