The leading voice in banking committed to combatting financial crime
Global Banks,
Global Standards
Wolfsberg Group

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.

Banco SantanderBank of AmericaBarclaysCitiDeutsche BankGoldman SachsHSBCJP Morgan ChaseMUFGSociete GeneraleStandard CharteredUBS
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Concrete hands-on guidance by practitioners,
for practitioners

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Resources published

CBDDQ & 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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Resources

Wolfsberg Response to the FBAs’ Notice of Proposed Rulemaking for the AML Program Rule

2024

Response to the Financial Stability Board’s (FSB) Consultations on Regulating and Supervising Cross-border Payment Services and Data Frameworks Alignment

2024

Wolfsberg Response to the Consultation on FinCEN’s Notice of Proposed Rulemaking (NPRM) for the AML/CFT Program Rule

2024

The Wolfsberg Group Statement on Effective Monitoring for Suspicious Activity

2024

Wolfsberg Group Response to the UK's HMT Consultation on the MLRs

2024

Wolfsberg Group Response to FATF public consultation on R.16/INR.16

2024

Wolfsberg Group Principles for Auditing for Effectiveness

2024

Wolfsberg Group on Countering Terrorist Financing

2024

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News

Appointment of the next Executive Secretary to the Wolfsberg Group

![](https://db.wolfsberg-group.org/assets/ba64279f-c541-46e9-a939-afe194e6dc9a) 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.”

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Local 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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Applying 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.

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