Most self-respecting money-launderers charge ten per cent. At CBA they charged $22 a trade, that is $22 for every remittance to Hong Kong.

In other words, CBA – the winner of last year’s Australian Financial Review Innovation leadership award – charges its average Aussie mortgage-holder more in fees than its average Aussie meth-lab customer.

The real story of how the bank risked its reputation – then blamed it on a “computer glitch” is here, a first class investigation by Nathan Lynch of Thomson Reuters’ Financial Crime and Risk, Regulatory Intelligence division.

Smart Laundromat: The inside story of CBA money-laundering scandal

We don’t know how much of the $8.9 billion laundered by the bank was proceeds of crime. As most non-criminals don’t sit on milk crates feeding ten grand at a time into an ATM, let’s be generous and assume only 50 per cent of that money was laundered.

At a typical rate of 10 per cent, a money-laundering syndicate would have picked up $450 million to launder $4.5 billion. Let’s not forget these deposits are not in the least ‘sticky’, they don’t stick around that is, so the bank doesn’t make much of a profit. It is high-risk, low-grade business.

Now, for this paltry margin, CBA faces regulatory investigations in Malaysia and Hong Kong (both are underway according to sources). It faces a lawsuit from AUSTRAC, a class action from shareholders, a possible action against directors from corporate watchdog ASIC and an inquiry by APRA.

One wonders what APRA has been doing until now as the prudential regulator is supposed to receive quarterly risk reports from CBA and must have missed all the shenanigans. For its part, ASIC may, in a bid to play catch-up with AUSTRAC and the AFP, might even have a swing at director bans (at the apex of the white collar jungle, a ban is as savage as the death penalty; the shame, the shame).

Then there is the spectre that the US Justice Department may get involved as it did in the aftermath of the Beijing Olympics corruption claims swirling around BHP. Sources told michaelwest.com.au that US authorities had already approached the bank with an inquiry.

Foreign Bribery: Australia’s loss is America’s gain

If there is a US counter-party involved in the CBA transactions with Hong Kong, the CBA might find itself in the cross-hairs of US regulators too. Maybe even a distant transaction by CBA in US money markets might open the legal avenue.

Surely the bank would have been better off sticking to those good old fat and reliable residential mortgages.

The standard fee for withdrawing cash at an ATM overseas is $5 plus 3 per cent of the transaction value so, on a $10,000 CBA money-wash to Hong Kong, the fees were $22 but, on a $10,000 withdrawal by an ordinary (non criminal) Aussie customer in Hong Kong, the fees are $300 (plus the $5 per transaction).

Further to this risk and reward perspective, establishment fees on an Equity Unlock Loan for Seniors are $950. So it would take 43 illegal meth-lab transactions through the hole-in-the-wall at $22 a pop to almost equal the amount the bank makes from aged pensioners for the pleasure of “unlocking the equity” in their home and reaping interest rate charges from the consequent loan.

The motivation is hard to fathom. Just a catastrophic failure of compliance and risk, a failure which will cost shareholders dearly … besides the teeny-weeny hit to those responsible: directors and executives.