Global Standards
Who we are
The Wolfsberg Group is an association of 12 global banks which aims to develop frameworks and guidance for the management of financial crime risks.
Concrete hands-on guidance by practitioners,
for practitioners
Key Areas of Work
Working Groups
We produce guidance and standards to support the industry and other stakeholders in the management of financial crime risk.
Read moreCBDDQ & FCCQ
Developed 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.
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Wolfsberg Response to the FBAs’ Notice of Proposed Rulemaking for the AML Program Rule
Response to the Financial Stability Board’s (FSB) Consultations on Regulating and Supervising Cross-border Payment Services and Data Frameworks Alignment
Wolfsberg Response to the Consultation on FinCEN’s Notice of Proposed Rulemaking (NPRM) for the AML/CFT Program Rule
Wolfsberg Group Response to the UK's HMT Consultation on the MLRs
Wolfsberg Group Response to FATF public consultation on R.16/INR.16
Wolfsberg Group Principles for Auditing for Effectiveness
Wolfsberg Group on Countering Terrorist Financing
News
Wolfsberg Response to the FBAs’ Notice of Proposed Rulemaking for the AML Program Rule
The Wolfsberg Group appreciates the opportunity to comment on FBAs’ Notice of Proposed Rulemaking for the AML Program Rule. We strongly believe that a proposed rule that implements Congress’ intention for the AML Act has the potential to generate a paradigm shift to bring about more effective outcomes and better oversight of the financial system, thereby protecting people and communities from financial crime related threats. The best way to execute this vision is by allowing FIs to implement a flexible risk-based approach, such that resources are appropriately allocated to where risks are the greatest and where priorities have been identified. The Program Rule is the cornerstone of a new AML/CFT regime and there will need to be other changes necessary to realise its benefits – not least, revisions to the FFIEC Examination Manual, and the roll out of examiner training; we look forward to working closely with the FBAs on the next steps throughout this journey.
Read moreWolfsberg Response to the Financial Stability Board’s (FSB) Consultations on Regulating and Supervising Cross-border Payment Services and Data Frameworks Alignment
The Wolfsberg Group (the Group) is pleased to provide a response to the FSB’s consultations on Recommendations for Regulating and Supervising Bank and non-bank Payment Service Providers Offering Cross-border Payment Services, and Recommendations to Promote Alignment and Interoperability Across Data Frameworks Related to Cross-border Payments. The business of cross-border payments is core to many of our members and is more complex than may appear at first glance and we welcome the opportunity to be part of the dialogue on this topic and contribute our members’ expertise gained by through processing many millions of payments every month. As set out in previous publications, the Group believes strongly in the principle of ‘same business, same risk, same rules’ to ensure a level playing field across the different types of entities that facilitate cross-border payments and we welcome the issuance of clear guidance around the common practice of payment bundling for all parties involved that sets out clear roles and responsibilities for parties within the payment chain as they relate to bundled payments. All parties to a payment chain have obligations that should be explicit, including the payment market infrastructures or financial market infrastructures that are used to send payment information.
Read moreWolfsberg Response to the Consultation on FinCEN’s Notice of Proposed Rulemaking (NPRM) for the AML/CFT Program Rule
The Wolfsberg Group appreciates the opportunity to comment on FinCEN’s Notice of Proposed Rulemaking (NPRM) for the AML Program Rule. We strongly believe that a proposed rule that implements Congress’ intention for the AML Act has the potential to generate a paradigm shift to bring about more effective outcomes and better oversight of the financial system, thereby protecting people and communities from financial crime related threats. The best way to execute this vision is by allowing FIs to implement a flexible risk-based approach, such that resources are appropriately allocated to where risks are the greatest and where priorities have been identified. We look forward to working closely with FinCEN on the next steps throughout this journey.
Read moreCBDDQ/FCCQ Guidance Materials now available in German
The Wolfsberg Group is pleased to announce that the CBDDQ Guidance, the CBDDQ Glossary and the CBDDQ/FCCQ FAQs are now available in German. You can find the links to the each of these documents below. Wir freuen uns, Ihnen mitteilen zu können, dass die Leitfäden (FAQs, Glossar und Anleitung) des CBDDQ und des FCCQ nun auch ins Deutsche übersetzt wurden. Bitte beachten Sie, dass die deutschen Übersetzungen jeweils Referenzversionen der englischen Originaldokumente sind, um die Verwendung des weiterhin ausschließlich in englischer Sprache zur Verfügung gestellten CBDDQ zu erleichtern. Sollten Sie daher Abweichungen der deutschen Versionen zu den englischen Originalen feststellen, so genießen die englischen Sprachfassungen stets Vorrang.
Read moreApplying the Wolfsberg Correspondent Banking Due Diligence Questionnaire in Brazil
The Wolfsberg Group (the Group) has engaged with [Abracam](https://www.selo.abracam.com/) (The Brazilian Foreign Exchange Association) to better understand their proposal to introduce a process to validate local institutions’ responses to the Wolfsberg Correspondent Banking Due Diligence Questionnaire (CBDDQ), with the validation performed by an independent auditing company. This initiative has seen Abracam working alongside other local entities, highlighting the CBDDQ's comprehensive coverage of the essential aspects of an obliged entity’s financial crime compliance control framework. A key part of this collaboration has been the promotion of high standards in the foreign exchange market through the assessment and certification of the obliged entity’s AML program, which can be enhanced by the application of the CBDDQ – a market segment outside the CBDDQ’s original design. The Central Bank of Brazil recognizes the improvement in the AML programs that came with Abracam‘s initiative, marking a significant advancement in the country's efforts to combat financial crimes. The Group is an association of 12 global banks committed to developing frameworks and guidance for the management of financial crime risks. The origins of the Group's CBDDQ date back to 2002, when the Group published its first Correspondent Banking Principles, in which the Group articulated its vision for, and encouragement and development of, an international due diligence registry for financial institutions. Since that time, what is now known as the CBDDQ has become the industry standard in correspondent banking due diligence. The CBDDQ has been recognised by the Basel Committee on Banking Supervision (BCBS), the Committee on Payments and Market Infrastructures (CPMI), the Financial Action Task Force (FATF) and the Financial Stability Board (FSB) as an “effective and efficient tool to support due diligence processes” that “will help to address the decline in the number of correspondent banking relationships”. The leadership from Abracam, in collaboration with the Central Bank of Brazil and working with local industry associations, to promote an assessment of the information contained in the CBDDQ is a welcomed development in Brazil and in the wider region. The Group looks forward to continuing the dialogue with Abracam, industry associations, and key regulatory bodies in the region to further the principles set out by the Group on an effective financial crime compliance framework.
Read moreThe Wolfsberg Group Statement on Effective Monitoring for Suspicious Activity
The Wolfsberg Group is delighted to publish a Statement on Monitoring for Suspicious Activity in line with the Wolfsberg Factors from 2019. The Group does not believe that the value being derived from the (constantly increasing) volume of SARs/STRs is contributing proportionately to effective outcomes in the fight against financial crime. While the concept of effectiveness has been discussed for many years by lawmakers, regulators, supervisors, standard setters as well as the private sector, the Group believes it has yet to be fully integrated into the overall FCRM framework which will require acceptance and alignment across public and private sectors. This paper seeks to describe how consideration of the Wolfsberg Factors can be translated into a more effective approach to Monitoring for Suspicious Activity (MSA). We have deliberately chosen to characterise this as MSA to cast a wider net than just Transaction Monitoring because customer behaviour and customer attributes, when combined with the consideration of transactions, can provide a broader insight into potentially suspicious activity. Transaction Monitoring is therefore a sub-set of MSA, which might also include concepts such as ongoing Customer Due Diligence (CDD). This paper encourages all parties to be proactive in the development of innovative techniques and supporting technologies which we believe will deliver more effective end-to end risk detection capabilities.
Read moreWolfsberg Response to the UK's HMT Consultation on the MLRs
The Wolfsberg Group is pleased to announce the submission of its response to the UK’s HM Treasury consultation on improving the effectiveness of the Money Laundering Regulations 2017 (MLRs). This consultation is part of a broader initiative under the Economic Crime Plan 2023-26. Our response addresses two core themes of the consultation: making customer due diligence more proportionate and effective, and strengthening system coordination. We welcome the opportunity to contribute to these crucial discussions, aiming to increase the effectiveness and proportionality of the regulations for both regulated firms and their customers, thereby supporting the ongoing fight against economic crime.
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