ASIC has accepted a variation to an enforceable undertaking provided by National Australia Bank in 2016 relating to its wholesale spot foreign exchange business, after an independent expert's report identified significant deficiencies in NAB's remediation program.  As a result NAB has had to accept an additional undertaking to prepare an updated program that adequately addresses all required components. This updated program will then be subjected to further assessment by the independent expert. On 29 March 2018, the independent expert reported on NAB's spot foreign exchange program, noting significant deficiencies regarding its: governance, risk management and compliance framework; policies and procedures; risk management practices; and, human resource management.  The expert's report states "progress in developing the program has been slow" and that the program "appears to have evolved iteratively during 2017, rather than through a well-defined process", according to a statement circulated by ASIC.