NAB and ASIC amend Spot FX Enforceable Undertaking



NAB and the Australian Securities and Investments Commission (ASIC) have agreed to amend the Enforceable Undertaking (EU) entered into in December 2016 regarding the bank’s Spot Foreign Exchange (FX) trading.

The amendment extends the timeframe for NAB to provide its proposed program of changes to its systems, controls, training, guidance, and frameworks for monitoring and supervising employees of its Spot FX business for assessment by an independent expert appointed by ASIC.

NAB Group Chief Risk Officer, David Gall, said NAB is firmly committed to working with ASIC to strengthen its Spot FX business.

“We welcome the feedback received from the independent expert in its initial report, which has helped us identify areas where we can do better to implement the program of changes,” Mr Gall said.

Changes that NAB has already implemented include:

  • Separating the Compliance team from the FX Operational Risk team so that our compliance officers have more time to focus on oversight and monitoring risks;
  • Repointing the FX Monitoring and Surveillance team to the Chief Compliance Officer, which improves the oversight, tools, systems, and advice bankers use to identify, manage, and monitor risks;
  • Improving the operating model, structure, and resourcing of the program of changes; and
  • Improving systems that assess risk.

“The program of changes to our Spot FX business is a crucial component of simplifying and improving the effectiveness of the bank’s controls and risk management systems, so that customers can continue to have full confidence in doing business with us,” Mr Gall said.

“We strongly support a well-functioning and fair global FX market, and take our role in upholding transparency and efficiency seriously.”

The program of changes aligns with NAB’s commitment to the Foreign Exchange Global Code. NAB is also committed to the work of the FICC Markets Standards Board (FMSB), being the first Australian Bank to join the Board in April last year.



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