Global Banks: Global Standards

The Wolfsberg Group is an association of thirteen global banks which aims to develop frameworks and guidance for the management of financial crime risks, particularly with respect to Know Your Customer, Anti-Money Laundering and Counter Terrorist Financing policies.

The Group came together in 2000, at the Château Wolfsberg in north-eastern Switzerland, in the company of representatives from Transparency International, including Stanley Morris, and Professor Mark Pieth of the University of Basel, to work on drafting anti-money laundering guidelines for Private Banking. The Wolfsberg Anti-Money Laundering (AML) Principles for Private Banking were subsequently published in October 2000, revised in May 2002 and again most recently in June 2012. There is also an Asia Pacific chapter of the Group, established in January 2019. Its work complements that of the wider Wolfsberg Group. It provides an important forum for discussion of effective financial crime risk management in Asia Pacific and promotes understanding of Wolfsberg Group publications across the region. 

Since the first set of AML Principles was released, the Group has published a significant number of documents, whether in the form of Principles, Guidance, Frequently Asked Questions (FAQs) or Statements. These can all be found on this website and include, amongst many others, a Statement on the Financing of Terrorism, Anti-Money Laundering Principles for Correspondent Banking, Guidance on a Risk Based Approach for Managing Money Laundering Risks, FAQs on Politically Exposed Persons (PEPs), Trade Finance Principles, Guidance on Anti-Bribery & Corruption Compliance Programmes and a statement endorsing measures to enhance the transparency of international wire transfers to promote the effectiveness of global AML and CTF programmes.

Materials published by the Wolfsberg Group are designed to provide financial institutions (FIs) with an industry perspective on effective financial crime risk management.

There are a number of ways FIs can seek to adhere to the various documents published by the Wolfsberg Group. However, the means by which each FI choses to adopt these documents must make sense for each individual firm, recognising that one size doesn't fit all and that each FI's risk mitigation strategy must be tailored to meet its risk appetite.

The Wolfsberg Group does not advocate that FIs simply adopt each publication, but rather each FI should consider the risks described, the applicable regulatory standards and their own defined risk management strategy. The materials published by the Wolfsberg Group offer a perspective through which FIs may identify gaps or new insights and consider to what extent these gaps or insights require attention. This is a matter for each FI. For example, an FI may identify alternative controls or other compensating measures to the ones suggested, for as long as the risks in question are adequately managed. Furthermore, the risks may indeed be different in different businesses, regions or countries.

Given the dynamic nature of the issues underlying financial crime risk, the Wolfsberg Group reviews and revises its published materials from time to time. FIs should note publication changes and consider how those changes might be addressed within an FI's risk management strategy. The same  applies to other interested parties which may have used, referred to or otherwise adopted any of the Wolfsberg Group's publications.

For background information on the Wolfsberg Group and its work, you may find it useful to read the attached articles "The Wolfsberg Group" by Hans-Peter Bauer and Gemma Aiolfi and "The PrivateSector becomes active: The Wolfsberg Process" by Mark Pieth and Gemma Aiolfi.

Back Office Consolidation
Controls for New Payment Methods
Credit Cards
DFS 504 Rule
Digital Identity
Future of Surveillance
Models & Methodologies
Negative News Best Practice
Retail Banking
RFI Benchmarking
Role of FCC professional
Source of Wealth/Source of Funds
Tax Transparency
Terrorist Financing and High Risk Charities
Trade Based Money Laundering
Vendor Procurement Due Diligence / ABC Control Framework