Throughout 2013 high value cash transactions that should have been reported to AUSTRAC were allegedly passing undetected through Commonwealth Bank's expanding fleet of intelligent deposit machines across the country.Matthew Keaney, then the bank's head of financial crime management, around that time canvassed his concerns over the global crackdown on money laundering at a round table of fraud and security executives hosted by IBM Australia.A transcript of the Sydney meeting, prepared by FST Media in July 2013, records Keaney's prescient comments - made after several international banks had then copped multi-billion dollar penalties for not complying with anti-money laundering laws."The issue that keeps me awake at night from a reputational perspective is not hacktivists, but it is the anti-money laundering, it is the sanctions that we have seen impact Barclays, the HSBC, and others," Keaney told the IBM-sponsored forum."That is the one thing that I think has a true, real, opportunity to negatively impact brand, value and reputation," he said.While Keaney is rarely mentioned in media coverage of the recent legal action taken against CBA by anti-money laundering regulator AUSTRAC, internally he has been a key player in the bank's efforts since August 2015 to make the bank's operations compliant.In his current role as general manager of financial crime services, Keaney - according to his LinkedIn profile - is accountable for coordinating CBA's "operational services relating to anti-money laundering, counter-terrorism financing and sanctions management".Official documents posted on the CBA website confirming the bank's authority to maintain correspondent accounts with US banks also describe Keaney as the "AML/CTF Compliance Officer".AUSTRAC's statement of claim against the bank, in a suit commenced earlier this month, includes allegations that organised crime syndicates exploited weaknesses in CBA's banking systems by opening fraudulent accounts and laundering millions of ill-gotten cash."It is essential to the integrity of the Australian financial system that a major bank such as CommBank has compliant and appropriate risk-based systems and controls in place to deter money laundering and terrorism financing," the regulator stated in documents filed to the Federal Court on 3 August.According to the transcript of the 2013 round table, Keaney asserted that CBA had "a very good sense" of how much fraud in the retail banking business was costing the company."I think that particularly around retail banking we have a very good sense of how much fraud costs us; we have a very good sense of our appetite for how much we are prepared to lose."And, we have very good measures by which we can manage that day-to-day," he said.Keaney also revealed that fraud losses absorbed by Commonwealth Bank had not changed much over the ten years to 2013."The amount of money that we would lose to external fraud today is the same as we were losing ten years ago," he said."And you think about the growth of the bank and its businesses in that time, that is a pretty good effort."Keaney did not appear in that forum to comment directly on the performance of the bank's money laundering detection systems.The meeting