ANZ risk culture has been under the spotlight for years. In December 2025, the Federal Court ordered the bank to pay A$250 million in penalties, the largest ASIC has ever secured against a single company. Then, in April 2026, the first independent report on ANZ’s repair program came back mostly amber.
Fittingly, that report uses traffic lights. So this story does too: red for what went wrong, amber for the repair job, and green for what’s getting better.
Red: what went wrong
The court found widespread misconduct and systemic risk failures affecting the Australian Government, taxpayers and at least 65,000 retail customers (ASIC, December 2025).
The biggest penalties came from a A$14 billion government bond deal. ANZ acted unconscionably and overstated its bond trading data to the government by billions of dollars for nearly two years. That earned a record A$80 million penalty for unconscionable conduct. On the retail side, ANZ failed to respond to hundreds of hardship notices and didn’t refund fees charged to thousands of customers who had died.
Red: why ANZ risk culture let it happen
An independent review by McKinsey looked for the root causes. It found a reluctance to challenge and to deliver bad news. It also found a focus on keeping up a “good news culture” that could hide problems from decision makers (Capital Brief, November 2025).
In other words, the problem wasn’t missing information. It was information that people didn’t feel safe passing up.
Amber: the repair job
ANZ launched its People, Accountability, Customers and Trust program, known as PACT, to fix these weaknesses. In April 2026, independent reviewer Promontory published its first report. Of seven workstreams, only two were rated green, four were amber and one was red (BankingDay, May 2026).
The report also pointed to difficulty bringing in specialist skills fast enough (Starling Insights, May 2026). Meanwhile, APRA is holding a A$1 billion capital add-on until it’s satisfied the reforms have worked.
Green: what ANZ has done
ANZ admitted the misconduct early and apologised. Its board cancelled A$32 million in bonuses for current and former senior leaders (Brightlaw). CEO Nuno Matos has said the amber ratings reflect normal project dynamics, and that the bank remains fully committed and on track.
The statistic behind the good news culture
In September 2026, GoTo released The Pulse of Work in 2026, based on 2,500 employees and IT leaders. It found that 83% of employees fear being fired for a mistake made with AI. Moreover, 31% feel pressure to stay quiet when AI gets something wrong.
The tools change, but the fear stays the same. When people worry that mistakes will cost them their job, they hide them. That’s exactly how a good news culture forms.
What MoodyBot could have saved from ANZ risk culture failures
MoodyBot, the AI layer inside Moody At Work, reads anonymous daily mood check-ins across teams. It doesn’t check bond trades or customer files. Instead, it tracks how people feel at work every day, with no names attached.
In a bank like ANZ, MoodyBot could have flagged unease in trading, operations and customer teams. It could also have shown check-in reasons clustering around pressure, fear of raising problems or being told to keep things positive. Finally, it could have shown the gap between the good news going up and the mood on the floor.
A good news culture filters what leaders hear. Anonymous daily data goes around that filter.
| Risk | Publicly reported loss | Model assumptions | What MoodyBot could have saved |
|---|---|---|---|
| Court penalties | A$250m ordered in December 2025 | 60% to 80% linked to risk culture (ASIC and the court pointed to systemic risk failures); 20% to 40% chance early signals lead to action (a very large bank) | A$30m to A$80m |
| Capital add-on | A$1bn held by APRA until reforms are proven | Capital set aside, not money lost | Not counted |
| Repair program | Multi-year PACT program | Cost of fixing the problem, not a loss | Not counted |
| Executive bonuses | A$32m cancelled | Money kept by the bank, not lost | Not counted |
| Total quantified | A$30m to A$80m |
How we built the numbers: A$250m x 60% x 20% gives A$30m. Likewise, A$250m x 80% x 40% gives A$80m. We kept the early action probability low because ANZ’s problems spread across many divisions and many years.
What every leadership team can learn
If everything you hear is good news, that’s a warning sign in itself. People rarely lie to their leaders. They just stop telling them the hard parts. Therefore, the most useful data is often the data nobody had to put their name to.
Another Australian board learned this the hard way, as we wrote in the Mineral Resources governance story.
ANZ risk culture FAQs
Why was ANZ fined A$250 million? In December 2025, the Federal Court ordered ANZ to pay A$250 million for misconduct in a government bond deal, false bond trading data and failures affecting at least 65,000 retail customers.
What is a good news culture? A McKinsey review of ANZ found staff were reluctant to challenge and to deliver bad news, and that a focus on good news could hide problems from decision makers.
Do workers hide mistakes? According to GoTo’s September 2026 research, 83% of employees fear being fired for an AI mistake, and 31% feel pressure to stay quiet when AI gets something wrong.
Sources: GoTo, The Pulse of Work in 2026 (15 September 2026); ASIC (19 December 2025); Capital Brief (November 2025); Promontory first report (30 April 2026); BankingDay (May 2026); Starling Insights (8 May 2026); Brightlaw.
All factual claims are sourced from publicly available reporting. ANZ’s representatives have stated that the failings were not good enough, have apologised to customers and the government, have held relevant executives accountable, and have said the bank remains fully committed to its PACT program. MoodyBot projections represent an independent illustrative probability model based on publicly reported information and are not guaranteed outcomes.