The Wolfsberg Group is an association of 12 global banks which aims to develop frameworks and guidance for the management of financial crime risks.
Learn moreLearn moreWe produce guidance and standards to support the industry and other stakeholders in the management of financial crime risk.
Read moreDeveloped and published by the Wolfsberg Group, the Correspondent Banking Due Diligence Questionnaire (CBDDQ) seeks to help Financial Institutions conducting due diligence on Correspondent Banking relationships, as per regulatory requirements and their own internal policies and procedures.
Learn moreLearn moreIn today’s more than ever interconnected world, the geopolitical landscape is fast-evolving, influencing economic, regulatory and financial crime frameworks globally. After a thorough exercise, the Wolfsberg Group is pleased to announce the publication of its updated Country Risk Frequently Asked Questions (FAQs). The revised FAQs provide a comprehensive understanding of the implications of country risk in the context of anti-money laundering (AML) and counter-terrorism financing (CTF) measures, including customer due diligence (CDD) requirements. The updated document specifically highlights: • Clearer delineation of country risk within the wider context of CDD and enhanced due diligence EDD; • Criminal indicators, political and regulatory factors which should be considered when developing a methodology to evaluate country risk; • Sanctions considerations and their impact in the context of AML/CTF country risk; • The need for a strong governance enabling an unbiased approach towards country risk; • Practical guidance combined with clear roles & responsibilities for financial institutions. We hope that the FAQs will play a pivotal role in the industry’s challenges in assessing and effectively mitigating country risk in the respective institutional AML/CFT frameworks.
Read moreTransparency in transfers of funds and crypto-assets is crucial for managing financial crime risk, as the 2023 Wolfsberg Group Payment Transparency Standards outline in detail. We are grateful for the opportunity to provide feedback on the “Travel Rule Guidelines” drafted by the European Banking Authority (EBA) to support the implementation of Regulation (EU) 2023/1113 and promote a common understanding of the requirements across all participants in transfer chains and competent authorities. Focusing primarily on Payment Service Providers (PSPs) and Intermediary Payment Service Providers (IPSPs), the Group offers detailed suggestions on how the Guidelines may be further improved in the following areas: - Acknowledging the various roles played by PSPs in a transfer chain and the different level of information available to each. This is particularly relevant for IPSPs facilitating payments for parties who are not their customers. - Addressing the potential unintended consequences of the new requirements around batch payments. - Requiring additional information on the payer to be included only when account number, name and address are insufficient to identify the person. - Stressing the importance of ex-post monitoring including the fact that it does not delay the processing of payments. - Clarifying terminology.
Read moreWe are pleased to announce that the Executive Summary of the Wolfsberg ABC Guidance has been translated into Japanese. Where a perceived difference exists between the English language original and this translation, the English language version prevails.
Read moreThe Wolfsberg Group Secretariat is pleased to announce that the primary delegates of the Wolfsberg Group member banks have elected Jennifer Calvery, HSBC’s Group Head of Financial Crime Risk and Compliance, and Joe Salama, Deutsche Bank’s Global Head of Anti-Financial Crime and Group Anti-Money Laundering Officer, as the new Co-Chairs of the Group. Jennifer and Joe succeed William Langford, MUFG Bank’s Global Head of Financial Crimes Compliance and Chief Compliance Officer for the Americas, whose term concluded at the end of 2023, and Carolina Garces Monterrubio, whose term concluded when she left Santander at the end of 2023. The Wolfsberg Secretariat thanks William and Carolina for their leadership and energy on behalf of the Wolfsberg Group. Jennifer is Group Head of Financial Crime Risk and Compliance. Before joining HSBC in 2016, Jennifer was the Director of the Financial Crimes Enforcement Network (FinCEN), the national financial crime regulatory agency housed within the US Department of the Treasury. Prior to FinCEN, Jennifer spent 15 years at the US Department of Justice. Joe Salama is the Global Head of Anti Financial Crime and Group Anti-Money Laundering Officer. Joe joined Deutsche Bank in 2010 and has since held a number of roles including as General Counsel for Americas and Global Head of Litigation and Regulatory Enforcement.
Read moreWe are pleased to announce the publication of the updated guidance for Swift Relationship Management Application (RMA) due diligence. Changes have been made to keep pace with technical changes occurring as the industry moves to the ISO20022 standard (specifically the fact that, unlike MT messages, the new “MX” messages must all be signed and will therefore all require an RMA). The updated Guidance also provides a clearer, more risk-based approach to RMA due diligence. The prior version of this guidance, published in 2016, has now been retired. This document is intended to provide broader guidance to financial institutions for managing non-customer RMAs and should be read as a supplement to the Wolfsberg Financial Crime Principles for Correspondent Banking issued in 2022.
Read moreWe are pleased to announce that the CBDDQ and FCCQ’s Guidance materials (FAQs, Glossary and Guidance) have been translated into French and Japanese to widen their accessibility. Where a perceived difference exists between the English language original and the translation, the English language version prevails. Nous avons le plaisir de vous annoncer que les documents relatifs aux CBDDQ et FCCQ (FAQ, Glossaire et Guide) ont été traduits en français afin d’en élargir leur accessibilité. Lorsqu’une différence est perçue entre l’original en langue anglaise et la traduction, la version en langue anglaise prévaut. コルレス銀行業務デューディリジェンス質問票(CBDDQ)および金融犯罪コンプライアンス質問票(FCCQ)に関する各種資料(FAQs、用語集、質問票回答の手引き)の日本語版を提供させて頂きます。 もし日本語、英語間で記載内容や表現等に差分がある場合、英語版資料の記載をご参照ください。
Read moreOn 8th December 2023, the Wolfsberg Group and the Institute of International Finance (IIF) submitted a joint response to the FATF’s public consultation on its Risk-Based Guidance on Recommendation 25 (Beneficial Ownership and Transparency of Legal Arrangements). We believe that providing competent authorities and regulated entities with adequate, accurate (i.e. verified) and up-to-date Beneficial Ownership information is key to ensure the effectiveness of the whole system in combatting financial crime. Further, we believe that regulated entities should be able to rely on this information and that it should be available to support their financial crime risk management obligations including but not limited to customer due diligence. We are grateful to the FATF for their continued engagement with the private sector. Our responses to the specific issues referenced in the consultation, as well as some additional points of feedback, can be read below.
Read moreThe 2023 Wolfsberg Academy took place last week and featured enriching discussions on Effectiveness, De-Risking and Financial Inclusion, Payment Transparency, Human Trafficking, Virtual Assets, Sanctions and Sanctions Evasion, Complex Investigations, and Technology. We thank the Faculty for their time and hard work, all participants for their enthusiasm and productive contributions, and the UBS Center for Education and Dialogue in Wolfsberg (Switzerland) for their hospitality.
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