Under the order, the lender must also show it has bolstered its compliance function.

ANZ Banking Group will pay A$3 million ($2.3 million) and submit results of regular independent reviews of its systems and processes after billing thousands of wealth management clients for services they didn’t receive. 

The order, imposed by the Australian Securities and Investments Commission (ASIC), also requires ANZ to provide an audited attestation from senior management to show “reasonable assurance” that the lender has, since 2014, provided clients with documented annual reviews.

In addition, the bank must demonstrate that it has improved its compliance functions, ASIC said. 

ASIC deputy chair Peter Kell said: “Our report into fees for no service in October 2016 identified the major financial institutions' systemic failures in this area, which required affected customers to be fairly compensated and to be provided with the services that they have paid for.

“ASIC considered it critically important that improved systems and procedures be put in place to ensure this breach of trust could not re-occur.”

The regulator’s action is on the back of an investigation into ANZ’s “fees for no services” conduct related to the Prime Access package offered to financial planning clients from 2003. A key component of the offering, ASIC said, was a documented annual review of clients’ financial plans. 

The probe found that ANZ had failed to provide reviews to more than 10,000 Prime Access clients.

From as early as 2008, ANZ was aware of numerous circumstances in which reviews had not been provided, but continued to bill clients for the service until 2013 and did not report the breach until August 2013, ASIC said.