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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

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.

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Questionnaires

Our Correspondent Banking Due Diligence and Financial Crime Compliance questionnaires set an enhanced and reasonable standard for cross-border and/or other higher risk correspondent banking due diligence.

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Advocacy

We also work towards promoting cooperation between the private and the public sectors in the fight against illicit financial activity.

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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 EBA CP202311 Consultation Response

2023
English

Wolfsberg Group response to FATF Consultation relating to non-profit organisations

2023
English
CBDDQ

CBDDQ/FCCQ FAQs V3.0

2023
English
CBDDQ

CBDDQ Glossary v3.0

2023
English
CBDDQ

CBDDQ Guidance v2.0

2023
English
CBDDQ

FCCQ (Excel)

2023
English
CBDDQ

FCCQ (PDF)

2023
English
CBDDQ

CBDDQ (Excel)

2023
English

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News

Wolfsberg EBA CP202311 Consultation Response

The amended draft Guidelines on Money Laundering and Terrorist Financing (ML/TF) risk factors by the European Banking Authority (EBA) clarify that all credit and financial institutions, including crypto-asset service providers (CASPs), need to take steps to address their ML/TF risks. The Wolfsberg Group welcomes the opportunity to provide comments and suggestions to enhance these amendments based on the principle of ‘same risk, same activity, same supervision’.

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Wolfsberg Group Response to FATF Consultation relating to Non-Profit Organisations

In June this year, the FATF issued public consultations on revisions to R.8/INR.8 and a Best Practices Paper dealing with protecting non-profit organisation (NPOs) from potential terrorist financing abuse. The Wolfsberg Group is pleased to provide comment and input to this process and to have been part of the discussion around NPOs at the Private Sector Consultative Forum in May.

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Publication of the Executive Summary of the Wolfsberg ABC Guidance in Simplified Chinese

We are pleased to announce that the Executive Summary of the Wolfsberg ABC Guidance has been translated into Simplified Chinese. Where a perceived difference exists between the English language original and this translation, the English language version prevails.

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Wolfsberg Annual Forum 2023

The 2023 Wolfsberg Group Forum just wrapped up after three days of highly engaging discussions around the theme of ‘Innovation and Improvement’ in fighting financial crime. The meeting opened with a keynote address from Xolisile Khanyile, Director of the Financial Intelligence Centre in South Africa and Chair of the Egmont Group of Financial Intelligence Units, and also included a virtual address from T Raja Kumar, President of the Financial Action Task Force (FATF). In the beautiful setting of the UBS Center for Education and Dialogue in Wolfsberg, Switzerland, we reviewed several instances where new thinking and new approaches around the world are resulting in more effective outcomes. The panels and breakout sessions touched upon topics such as regulatory change, steps being taken by FIUs around the world to innovate, detection of sanctions evasion, requirements and expectations on VASPs, and holistic monitoring. Numerous sessions were dedicated to payment transparency. We would like to thank all our attendees and presenters for their engagement and expertise – there is nothing that quite compares to sharing these moments in person. Special thanks also to our hosts for the on-site support.

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Publication of the Wolfsberg Group Request for Information (RFI) Best Practice Guidance in Simplified Chinese

We are pleased to announce that the Wolfsberg Group Request for Information (RFI) Best Practice Guidance has been translated into Simplified Chinese. Where a perceived difference exists between the English language original and this translation, the English language version prevails. 我们很高兴地宣布，Wolfsberg Group 交易监测信息征询书（RFI）最佳实践指南已翻译成简体中文。如果英文原版和本译文之间存在明显差异，则以英文版本为准。

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Publication of the Wolfsberg Group Response to the CPMI Consultation on ISO 20022 Harmonisation Requirements for Cross-Border Payments

On 1 March 2023, the Bank for International Settlements’ Committee on Payments and Market Infrastructures (CPMI) launched a consultative report on ISO 20022 harmonisation requirements for enhancing cross-border payments. The Wolfsberg Group welcomes the opportunity to comment on the report and provide insight into the questions concerning financial crime compliance risk in today’s highly complex and intermediated payment landscape. You can read the Comment Letter [here](https://db.wolfsberg-group.com/assets/4bcbd5bb-4191-4630-b087-37dc0f48fbb1).

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Publication of the Wolfsberg ABC Guidance

Today the Wolfsberg Group is publishing its updated Anti-Bribery and Corruption Compliance Programme Guidance. This document updates the 2017 version and it is designed to promote a culture of ethical business practices and compliance with ABC legal and regulatory requirements. The Guidance is a risk-based approach for the adequate development and implementation of compliance programmes to prevent, detect, and report acts of Bribery and Corruption and identifies areas of elevated risk. While no ABC compliance programme can prevent or protect against Bribery and Corruption risks completely, and there is no one-size-fits-all solution, this guidance can help the industry mitigate Bribery and Corruption risks by using elements including but not limited to: An applicable firm wide ABC policy; Governance with roles and responsibilities and access to top management; Periodic risk assessment to assess the nature and extent of the Bribery and Corruption risks, the establishment of a controls environment covering risks associated with anything of value, third party providers and customer related transaction risks, investments and acquisitions; Training and awareness including the sharing of lessons learned from internal and external events for continuous evaluation of the compliance programme adequacy; and Monitoring and testing for compliance with controls to identify failure to act in a manner consistent with the financial institution’s business principles/policies/codes of conduct/applicable laws or regulations. The Guidance incorporates learnings from enforcement actions since 2017 with updates to the red flags section and expands the section on customer and transaction corruption risks. The document includes the need for financial institutions’ programmes to be continuously evolving, and a new section on identifying, reporting, and mitigating emerging Bribery and Corruption risks. Finally, the guidance has been aligned to current and evolving legal regulatory expectations with additional guidance for post-acquisition due diligence, the inclusion of guidance for financial institutions to include a holistic risk assessment and management as part of their control frameworks

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Publication of the Negative News FAQs in Simplified Chinese and Traditional Chinese

The Wolfsberg Group is pleased to announce that the Negative News FAQs has been translated into Simplified Chinese and Traditional Chinese. Where a perceived difference exists between the English language original and this translation, the English language version prevails. 沃尔夫斯堡组织很荣幸的发布公告，日前其官方网站已提供“负面新闻常见问答解答”的简体中文翻译版和繁体中文翻译版。该“负面新闻常见问答解答”内容以英文版本为准， 中文翻译仅供参考。 沃爾夫斯堡組織很榮幸的發佈公告， 日前其官方網站已提供「負面新聞常見問答解答」的簡體中文翻譯版和繁體中文翻譯版。該等「負面新聞常見問答解答」內容以英文版本為準， 中文翻譯僅供參考。

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