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.
Learn moreLearn moreResources
Wolfsberg Guidance on Payment Transparency - Roles and Responsibilities
Wolfsberg Group Response to FATF public consultation on AML/CFT and Financial Inclusion - R.1, 10 and 15
Defining Digital Assets FAQs
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
News
2025 Wolfsberg Forum: From strategic alignment to operational gains
**Summary** The 25th anniversary Wolfsberg Forum concluded on Friday, May 23, bringing together a select group of 100 leaders from around the world dedicated to disrupting financial crime. The Wolfsberg delegates were joined by public, private and civil society experts from Asia, Africa, the Middle East, Europe and the Americas to focus on resolving the core issues that continue to challenge the financial crime community. The Forum encouraged the participants to transition from problem setting and into problem solving through a series of panels connected by smaller breakout sessions. The breakout groups were balanced by supervisory, financial intelligence unit, law enforcement, and private and civil society voices to ensure the spectrum of stakeholder interests across the community were both raised and addressed. This included representation from traditional banks, fintech payment service providers, stablecoin issuers, and digital asset service providers. The themes covered by the Forum included: - Suspicious activity reporting reform. What are we trying to achieve with suspicious activity reporting? High quality leads or a “drag net” for big data analytics? And what are the distinct implications for private sector monitoring systems, FIUs, examiners, and law enforcement? - Why feedback matters and how we can advance, with a focus on private-to-private, public-to-public, and private-to-public frameworks. - Ensuring supervision and enforcement incentivise an effective approach to disrupting financial crime. - Reimagining the risk assessment to be more accurate, timely, and more valuable at the national level, at the enterprise-wide level for financial institutions, and for onboarding and maintaining customers. This included seeing the risk assessment as a “process, not product”, understanding how assessing risk coexists with assessing threats, and embracing risk-based supervision. Underscoring all the thematic areas was a specific focus on the application of the risk-based approach, the need to build trust, and how the distribution of financial crime risk across public, private and civil society actors both mitigates and exacerbates the fear of failure. The Forum closed with participants applying the insights gained from the sessions against a series of case studies from around the world. The studies highlighted the prevalence of fraud networks and the need to bridge the cultural “fiat-digital asset divide” to become more effective in disrupting financial crime and protecting society from scams. **Key areas of convergence and next steps** The following shared views emerged over the course of the three-day gathering: **- Making cost-benefit decisions on monitoring for suspicious activity will unlock the resources necessary to achieve law enforcement priorities and get bad actors out of the regulated financial system, while also enabling financial institutions to reduce wasteful spending.** More than half of the participants (60%) believe that a lack of clarity on the definition of “suspicion” leads to over and/or under-reporting of suspicious activity. **- Redirecting some of those resource gains to private-public/private-private partnerships will enable us to better respond to threat actors with the necessary speed and agility.** Private-to-private information sharing, for example, was regularly referenced as a critical advancement, and giving credit to financial institutions during supervisory examinations was viewed as the best way to incentivize private-to-private information sharing. Also important to participants was the need for a legal safe harbour in doing so and ensuring that private-to-private initiatives were not "additive" but rather based on a financial institution redirecting resource away from ineffective financial crime controls. **- This will require us to pivot our collective culture based in “fear of failure” into one of rapid learning and continuous improvement.** Fear of failure across all stakeholders – from financial institutions to financial intelligence units to examiners – was viewed by many participants as a key blocker to progress, ultimately promoting the over-reporting of SARs/STRs (49%) by the private sector and the issuance of unnecessary observations or recommendations in examinations (45%) by supervisory authorities. **- The secret to pivoting our culture and making operational gains is maintaining and building upon the foundation of trust we established at the Forum.** Trust among key actors in the community is at an all-time high, but it needs to go further. The prevalence of public-private partnerships over the last several years has facilitated trust among the private, public and civil society sectors, debunking the myth that we’re not all on the same team and driving home the reality that our only opponents are the bad actors themselves. However, trust will need to continue to develop in order to make hard decisions on de- prioritisation and step away from activities that do not provide sufficient value. Seeking a common view among all stakeholders on risks and risk-ownership will be critical if we are to advance. **- Each of the 100 participants committed at the Forum’s end to take concrete action focused on translating this strategic alignment into tangible operational gains.** Wolfsberg committed in turn to organise smaller groups to further advance these key areas of convergence and raise substantive proposals to critical decision-makers at the national, regional, and international level. The Forum opened with remarks from Wolfsberg co-chair Emma Molvidson (UBS) and was closed by co-chair Jen Calvery (HSBC). Both chairs emphasized the critical role that Wolfsberg has played over the last 25 years and will continue to play in the future in using the Group’s convening power and dedication to collective action to ensure real change in the fight against financial crime. The Group is committed to maintaining the momentum built during the Forum and will continue to engage with the participants to realise tangible, operational gains in effectively and efficiently safeguarding the international financial system.
Read moreThe Wolfsberg Group elects a new Co-chair
Emma Molvidson, the Global Head of Financial Crime Prevention for UBS, has been elected as the new Co-Chair of the Wolfsberg Group, effective from January 1, 2025. Emma became the Global Head of Financial Crime Prevention at UBS in April 2023. She has held a variety of senior management roles at UBS over the past 14 years in Group Legal, the Investment Bank as well as leading Compliance & Investigations. “Emma provides a unique perspective within Wolfsberg, given her legal and investment bank background. I am thrilled to partner with her as co-chair and benefit from her experience as we continue to drive forward the effectiveness agenda of our member banks,” says Jen Calvery, current co-chair of the Group and Global Head of Financial Crime Risk and Compliance at HSBC. Prior to joining UBS, Emma was at Swiss Re and she also has a private practice background in corporate finance from Norton Rose in London and Paris. Emma succeeds Joe Salama at Deutsche Bank. The Wolfsberg Group thanks Joe for his dedication and support over the years, both from his time as co-chair and also as a primary delegate to the Group. “Joe’s enthusiasm and optimism for reform has had an immeasurable, motivational impact on the Group’s membership, and he will be missed,” says Ned Conway, the Executive Secretary at Wolfsberg. “But in replacing Joe, Emma provides continuity as an inspiring voice on the management committee that can also draw on a deep experience in the role of general counsel.”
Read moreWolfsberg Guidance on Payment Transparency - Roles and Responsibilities
Payments can flow in a variety of ways and involve many types of payment service providers, messaging systems and payment market infrastructures. This document provides an overview of the roles played by key actors in a payment chain. It also sets out their respective responsibilities to adhere to payment transparency standards across a sample of commonly observed payment flows and serves as a reference guide that can be used by all payment service providers, regulators, and standard setters. This guidance supplements, and should be read in conjunction with, the Wolfsberg Group Payment Transparency Standards published in October 2023.
Read moreWolfsberg Group Response to FATF consultation on AML/CFT and Financial Inclusion - R.1, 10 and 15
The Group agrees with the FATF’s goal to create an anti-money laundering/countering the financing of terrorism (“AML/CFT”) regulatory environment that reinforces the risk-based approach while also supporting financial inclusion. Requiring excessive AML/CFT measures that do not respond to the identified risks is inefficient and ineffective, while the unintended consequences of restricting under-served communities’ access to financial services decreases the reach and effectiveness of AML/CFT regimes. As noted in the Group’s original Statement on Effectiveness, an effective AML/CFT programme will “have the benefit of reducing friction on customers and helping governments with their objective of financial inclusion".
Read moreWolfsberg FAQs on Defining Digital Assets
Agreeing on a common lexicon in the digital assets space continues to be a challenge. Today the Wolfsberg Group shares a collection of Frequently Asked Questions (FAQs) on Defining Digital Assets in an Emerging Financial Crime Compliance Risk Environment, which captures how the Group's members conceive of and conceptualise key terms associated with digital assets -- in their engagement with policymakers, supervisors, regulators, and other FIs, and in developing their own policies and designing appropriate controls. These terms will serve as a reference going forward for subsequent work by the Group on the risks and associated controls for digital assets.
Read moreFrench translation of the updated Wolfsberg Group Payment Transparency Standards
The Wolfsberg Group has just published the French version of its 2023 Payment Transparency Standards. Discover the full press release and the translated document below. Where a perceived difference exists between the English language original and the translation, the English language version prevails.
Read moreAppointment of the next Executive Secretary to the Wolfsberg Group
The Wolfsberg Group announces today the appointment of its next Executive Secretary, J. Edward 'Ned' Conway, effective November 1st. Mr. Conway was most recently the Group Head of Financial Crime Compliance Framework and Policies at Banco Santander. His career in financial crime prevention began at the US Department of Defense, where he was a member of the Iraq Threat Finance Cell in Baghdad in 2007, and was then the resident threat finance analyst for a Special Operations Command Joint Task Force in Balad, Iraq, in 2009. In the private sector, Mr. Conway worked at PwC and Barclays before joining Santander. He collaborates regularly with the United Nations Office on Drugs and Crime, training financial intelligence units and related government agencies in the Americas, East and West Africa, the Middle East, and Southeast Asia. He also chairs the UN’s Private Sector Dialogue on the disruption of financial crimes related to crimes that affect the environment. Mr. Conway is a member of the ACAMS Advisory Board and the co-editor of the volume Counterterrorism and Threat Finance Analysis During Wartime (2015). At Wolfsberg, where Mr. Conway has been a delegate since 2019, he led the working group that produced the Guidance on Digital Customer Lifecycle Risk Management, and he played a key role in updating the Group’s Payment Transparency Standards in 2022. Alan Ketley will retire from his role as Executive Secretary since assuming the position in 2021. The members of the Wolfsberg Group are grateful for Mr. Ketley’s leadership over an important period of transition for the Group and during a critical moment of regulatory reform across the US, UK and the EU. From Wolfsberg co-chairs Jen Calvery (HSBC) and Joe Salama (Deutsche Bank): “Over his tenure, Alan has been able to advance the Group's focus on effectiveness with key supervisory authorities across the globe. Existing standards have been updated to respond to current challenges, and new guidance released under his leadership has focused the Group's energy on emerging areas of interest, all while increasing the accessibility of the Group's work by facilitating translations into various languages beyond English. We wish him all the best as he takes a well-deserved break from his decades of dedication to effective financial crime compliance.” 
Read moreLocal industry association, Abracam, promotes use of the Wolfsberg Correspondent Banking Due Diligence Questionnaire in Brazil by translating materials into Portuguese
The Wolfsberg Group (the Group) is pleased to announce that the supporting guidance for the Correspondent Banking Due Diligence Questionnaire (CBDDQ) has been translated into Portuguese (see links below). The translation of the materials has been led by Abracam ([The Brazilian Exchange Association](https://www.linkedin.com/company/abracamcambio/)), a non-profit entity in Brazil which represents financial institutions authorised to operate in the Brazilian foreign exchange market, their correspondents, and companies supporting foreign exchange activities. The translation of the CBDDQ guidance into Portuguese complements previous translations of the guidance into French, Japanese and Spanish and represents the Group’s efforts in supporting the adoption of the CBDDQ across the world. The Wolfsberg 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 industry initiative that can help address de-risking through the standardised application of KYC requirements. For Abracam, the translation of the CBDDQ supporting materials into Portuguese will help their joint initiative with other local industry associations, in collaboration with the Central Bank of Brazil in promoting higher standards in the Brazilian foreign exchange market by using the CBQQD as the underlying assessment framework. The Group’s Statement on Effectiveness makes clear that “an effective AML/CTF programme will also have the benefit of reducing friction on customers and helping governments with their objective of financial inclusion”. The initiatives from the Central Bank of Brazil, working through local industry partners like Abracam to support the use of CBDDQ as a common financial crime compliance framework, demonstrate this benefit in practice. The Group appreciates the leadership from Abracam in performing the Portuguese translation. The Wolfsberg 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.
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