Clayton Bank needs to send money overseas on behalf of its customers. In the past they have had around 80 correspondent banks that they can use to send money to different countries. Given the Know Your Customer (KYC) rules though, Clayton Bank has had to reduce the number of correspondent banks to 45 banks. But there appears to be time when staff have looked the other way or turned a blind eye when transactions did not feel quite right. Clayton Bank has also been fined $5 million by the regulator AUSTRAC in Australia, over allowing a number of international transactions that have been used to fund the purchase of drugs or gold/gemstones via trade-based contracts. The penalty seems to have been large commented Jack Turin the CEO of Clayton Bank. Despite this claim Jack Turin was paid a $3 million bonus in the recent year end.

The financial press and politicians have been stating how Clayton Bank had got their operations wrong. There have been calls for more accountability of senior staff within the bank such as the Board of Directors and Senior Management. AUSTRAC reported to the press that Clayton Bank had suffered reputation risk. Secretly, staff within the bank are also concerned that there may have been some multi-million-dollar transactions used to purchase illegal arms (guns etc.).

Please comment. 10 marks.

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