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
The 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.
Read moreWolfsberg 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.
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