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 moreThe Wolfsberg Group is pleased to provide feedback to the Financial Action Task Force on the proposed revisions to Recommendation 16 and its Interpretative Note. The payments industry has evolved significantly since these guidelines were first issued and we welcome the initiative to update them. We believe that ‘a payment is a payment’ and that any entity, regardless of how it is described or refers to itself, should be subject to R.16 in line with the principle of ‘same activity, same risk, same rule’. In our response we highlight the importance of future proofing the Recommendation by adopting ISO20022 terminology, of the vitally important role that operators of payment market infrastructure (PMIs) have to play because, quite simply, if mandated information cannot fit into a message, then either that PMI must build the capacity to handle the information or it should not permit activity that requires such information to use it. Our response also highlights the importance of using the right tool for the job at hand and not to try and use R.16 for controls that would be addressed more appropriately by R.10 on customer due diligence.
Read moreWe are pleased to announce that the CBDDQ and FCCQ’s Guidance materials (FAQs, Glossary and Guidance) have been translated into Spanish to widen their accessibility. Where a perceived difference exists between the English language original and the translation, the English language version prevails. Nos complace anunciar que los materiales orientativos (las Preguntas frecuentes o FAQ, el Glosario y la Guía) del Cuestionario de Diligencia Debida para Banca Corresponsal (CBDDQ por sus siglas en inglés) y del Cuestionario de Cumplimiento de Crimen Financiero (FCCQ por sus siglas en inglés) han sido traducidos al español para ampliar su accesibilidad. Cuando se perciba una diferencia entre el original en inglés y la traducción, prevalecerá la versión en inglés.
Read moreIn 2019, the Wolfsberg Group (the Group) published a Statement on Effectiveness that included three ‘Wolfsberg Factors’ that we believe should underpin any financial institution’s Anti-Money Laundering/Counter Terrorist Financing (AML/CFT) programme. The Group has continued to build on the Wolfsberg Factors in subsequent publications. The Group believes that Internal Audit can assist their financial institutions in the fight against financial crime by measuring Financial Crime Risk Management outcomes using the Wolfsberg Factors and has developed these Principles for Auditing a Financial Crime Risk Management Programme for Effectiveness under the Wolfsberg Factors. In considering these Principles Internal Audit will not only promote effective Financial Crime Risk Management within financial institutions, but equally support how supervisors may also seek to assess the effectiveness of their regulated entities and the industry as a whole. This was as a joint exercise between member banks’ second and third lines of defence, to provide financial institutions with a framework for such an assessment.
Read moreIn 2002, the Wolfsberg Group published a Statement on the Suppression of the Financing of Terrorism. We are pleased to announce that the document has been revised and updated to reflect changes in Counter-Terrorist Financing (CTF) measures and the evolving nature of public-private cooperation.
Read 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; • 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.
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