In the past, issues relating to culture and governance have led to large remediation costs, as well as penalties and operating restrictions imposed by regulators. ASIC recently commenced legal proceedings against three large banks: ANZ, for alleged breaches of the Credit Act related to its 'introducer program'; Westpac, for alleged widespread compliance failures across multiple lines of business; and Macquarie Bank for alleged failures to properly monitor and control third-party transactions on customers' accounts. In addition, the Reserve Bank of New Zealand (RBNZ) instructed the New Zealand subsidiary of Westpac (Westpac NZ) to commission an independent report into risk governance, which found material risks to effective risk governance and underinvestment in risk management capabilities. While the RBNZ noted that Westpac NZ had made some progress towards addressing these concerns, it expects them to continue prioritising the findings of the report.