Commonwealth Bank yesterday opened its public defence against the reams of anti-money laundering offences alleged by AUSTRAC in the statement of claim lodged in the Federal Court last week.The bank's most salient point was that its failure to report around 50,000 high-value banking transactions to the regulator was attributable to a software coding error on its fleet of Intelligent Deposit Machines.CBA revealed that the error persisted from May 2012 until September 2015 before it was corrected.Stock market investors appeared to take some heart from the bank's statements, driving up the company's share price by 80 cents or one per cent. CBA's scrip outperformed the broader market and moved in line with its major bank peers.However, the bank's statements are also notable for what they did not contain.There was no attempt to address AUSTRAC's charges that the bank failed to carry out basic risk assessments on IDMs before they were rolled out across the CBA network.Nor did the statements issued on Monday explain why the bank's compliance and risk management teams allegedly failed to monitor certain customers' accounts even after concerns about them were communicated to the bank by the Federal Police.AUSTRAC alleges that the bank allowed suspicious transfers to continue on accounts, which the Federal Police had already raised serious concerns about.The regulator also alleges that the bank did not monitor some accounts that its own internal systems had found to be at high risk of money laundering."Even after CommBank identified structuring on the deposits, and identified some of these accounts as belonging to suspicious money remitters or being part of a sophisticated money laundering syndicate, CommBank allowed transactions to continue," AUSTRAC alleges in documents filed in the Federal Court.The regulator's statement of claim is replete with such alleged offences under Australian anti-money laundering and terrorism financing laws.While no-one should doubt the bank's claim that it is taking the regulator's allegations "very seriously", institutional and retail shareholders will no doubt be raising fresh questions about the company's risk management culture and performance based on the information they were given in the 2016 annual report and at the last annual meeting.CBA's chronic problems of under-reporting high value transactions on customers' accounts were known within the bank by at least September 2015.So, why then was the bank so glowing in its assessment of its own performance in the 2016 annual report and at the AGM in Perth last November?Here's what former chairman David Turner told shareholders at the AGM:"It is an unspoken expectation that CBA is totally solid and safe, an ever present profile. "Its strength and stability are taken for granted."He went on: "People see it just like gravity. It's always there. "You don't go to sleep at night and expect to wake up slapped against the ceiling. "Here are three reasons why the Bank remains so stable…"There was also little in the annual report to indicate to shareholders that internal risk management specialists led by the bank's former chief risk officer, Alden Toevs, had been working through one of the