2024-07-15

Applying the Wolfsberg Correspondent Banking Due Diligence Questionnaire in Brazil

The Wolfsberg Group (the Group) has engaged with Abracam (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.