In a statement on the ASX, the bank said it admits to some of the allegations brought against it in August, including the 53,506 late threshold transaction report (TTR) submissions, but is contesting others.
"The defence focuses on key factual and legal matters in the claim," the statement said.
The bank said it agrees it was late in filing the 53,506 TTRs (which accounted for 2.3 per cent of the bank's TTRs during 2012 and 2015), that it did not "adequately adhere to risk assessment requirements for intelligent deposit machines" and admits (in whole or in part) to 91 allegations concerning suspicious matter reports, and 52 allegations concerning "ongoing customer due diligence".
However, the statement also says the bank does not accept that its failure to adhere to intelligent deposit machine risk assessment requirements amounts to eight separate contraventions as alleged by AUSTRAC, and denies 83 of the suspicious matter reporting allegations and 19 of the ongoing customer due dilligence allegations.
"We continue to fully co-operate with AUSTRAC in relation to our obligations under the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 and respect its role as a regulator," the bank said.
"We deeply regret any failure to to comply with these obligations. CBA is accountable for those deficiencies."
According to the statement, AUSTRAC has indicated "that it proposes to file an amended statement of claim containing additional alleged contraventions", and expects the court will set a timetable in order for the bank to file an amended defence.
"We will provide market updates as appropriate," the statement said.
