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.