AMP is counting on civil action directed by ASIC in preference to prosecution for alleged criminal beaches.The company "takes responsibility for its past failings and has taken steps to ensure that these failings do not recur," AMP Group Limited declared on Friday.But it is seeking to avert the most gross allegations of wrongdoing aired at the Hayne royal commission."AMP does not accept all of Counsel Assisting's open findings," AMP said in a summary, four page response. "AMP strenuously denies the allegation by Counsel Assisting that it is open to find that AMP has committed a criminal offence in providing the Clayton Utz report to ASIC. The issues raised in the fee for no service case study concerned matters that are almost entirely the subject of an ongoing ASIC investigation. "The investigation commenced in 2015 and has involved compulsory examination of numerous AMP current and former employees and the production of hundreds of thousands of documents to ASIC."In a longer analysis, AMP added that the "report is uncompromisingly direct and comprehensive and is the result of multiple employee interviews. It can only have been of assistance to ASIC in its investigation, and to counsel assisting in preparing cross-examination."But, "it contains serious adverse findings, including a number of inaccurate or misleading statements to ASIC."AMP explained that: "As AMP understands, ASIC was nearing completion of that investigation at the time the Royal Commission hearings commenced. AMP fully expects ASIC will deal with the serious matters being investigated in an appropriate manner consistent with ASIC's enforcement priorities and under a proper process with any affected parties having had the opportunity to be heard."AMP also argued that "the Terms of Reference for the commission state that the commissioner is not required to inquire into a particular matter to the extent that he is satisfied that the matter has been, is being, or will be, sufficiently and appropriately dealt with by another inquiry or investigation or a criminal or civil proceeding."AMP said that "the conduct of AMP and its Licensees in relation to the failure to turn off fees, including their communications with ASIC with regard to those issues, is the subject of an ongoing ASIC enquiry. There is no evidence before the commission to suggest that ASIC will not sufficiently and appropriately deal with that matter, and therefore the commissioner ought to be satisfied that ASIC will do so."