KUBR

RBA banknote subsidiaries fined over foreign bribery; ex-executives sentenced

Securency International Pty Ltd / Note Printing Australia · Banknote printing and polymer substrate

Regulatory breachGovernance failure

The case in brief

Visible before detection

    Checks that could have surfaced it, on hindsight

    1

    Counterparty existence

    Would have tested what services the overseas agents actually provided.

    Can mislead when: Real companies can be used as pass-throughs. Existence does not prove a real trade, so C6 and C7 still apply.

    2

    End-use tracing of funds

    Would have traced agent commissions onward to officials.

    Can mislead when: Kubr sees only the company's own accounts. Once money reaches a third party's bank, Kubr can flag the payee but cannot see the next hop without that party's consent.

    3

    Regulatory & litigation records

    Would have surfaced the 2009 media allegations and the AFP referral.

    Can mislead when: Court records lag and name spellings vary. A clean record can mean the problem has not reached court yet.

    Where Kubr services would have helped

    Verified Snapshot

    Offered in India
    • C4 Would have tested what services the overseas agents actually provided.
    • C8 Would have surfaced the 2009 media allegations and the AFP referral.

    Valuation context

    Offered in India
    • C4 Would have tested what services the overseas agents actually provided.
    • C8 Would have surfaced the 2009 media allegations and the AFP referral.

    Borrower monitor

    Offered in India
    • C6 Would have traced agent commissions onward to officials.
    • C8 Would have surfaced the 2009 media allegations and the AFP referral.

    Proceeds tracer

    Offered in India
    • C4 Would have tested what services the overseas agents actually provided.
    • C6 Would have traced agent commissions onward to officials.

    Mapped from the checks each service runs. A hindsight reading of public records, not a promise that the failure would have been found.

    A summary of public documents. It reports what the sources say. It is not Kubr's finding and not a statement of guilt.