According to the Complaint, Westpac Banking Corporation purports to provide various banking and financial services in Australia, New Zealand, Asia, the Pacific region, and internationally.

The Complaint alleges that Defendants throughout the Class Period made false and/or misleading statements and/or failed to disclose that: (1) contrary to Australian law, the Company failed to report over 19.5 million international funds transfer instructions to AUSTRAC, Australia's anti money-laundering and terrorism financing regulator; (2) the Company did not appropriately monitor and assess the ongoing money laundering and terrorism financing risks associated with movement of money into and out of Australia; (3) the Company did not pass on requisite information about the source of funds to other banks in the transfer chain; (4) despite being aware of the heightened risks, the Company did not carry out appropriate due diligence on transactions in South East Asia and the Philippines that had known financial indicators relating to child exploitation risks; (5) the Company's AML/CTF Program was inadequate to identify, mitigate and manage money laundering and terrorism financing risks; and (6) as a result, defendants' statements about its business, operations, and prospects, were materially false and misleading and/or lacked a reasonable basis at all relevant times.