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.
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The Wolfsberg Group Statement on Effective Monitoring for Suspicious Activity
Wolfsberg Group Response to the UK's HMT Consultation on the MLRs
Wolfsberg Group Response to FATF public consultation on R.16/INR.16
Wolfsberg Group Principles for Auditing for Effectiveness
Wolfsberg Group on Countering Terrorist Financing
Country Risk FAQs
Wolfsberg Group Response to EBA Consultation on Travel Rule Guidelines
Swift RMA Guidance
News
CBDDQ/FCCQ Guidance Materials now available in German
The Wolfsberg Group is pleased to announce that the CBDDQ Guidance, the CBDDQ Glossary and the CBDDQ/FCCQ FAQs are now available in German. You can find the links to the each of these documents below. Wir freuen uns, Ihnen mitteilen zu können, dass die Leitfäden (FAQs, Glossar und Anleitung) des CBDDQ und des FCCQ nun auch ins Deutsche übersetzt wurden. Bitte beachten Sie, dass die deutschen Übersetzungen jeweils Referenzversionen der englischen Originaldokumente sind, um die Verwendung des weiterhin ausschließlich in englischer Sprache zur Verfügung gestellten CBDDQ zu erleichtern. Sollten Sie daher Abweichungen der deutschen Versionen zu den englischen Originalen feststellen, so genießen die englischen Sprachfassungen stets Vorrang.
Read moreApplying 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.
Read moreThe Wolfsberg Group Statement on Effective Monitoring for Suspicious Activity
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.
Read moreWolfsberg Response to the UK's HMT Consultation on the MLRs
The Wolfsberg Group is pleased to announce the submission of its response to the UK’s HM Treasury consultation on improving the effectiveness of the Money Laundering Regulations 2017 (MLRs). This consultation is part of a broader initiative under the Economic Crime Plan 2023-26. Our response addresses two core themes of the consultation: making customer due diligence more proportionate and effective, and strengthening system coordination. We welcome the opportunity to contribute to these crucial discussions, aiming to increase the effectiveness and proportionality of the regulations for both regulated firms and their customers, thereby supporting the ongoing fight against economic crime.
Read moreWolfsberg Group Response to FATF public consultation on R.16/INR.16
The Wolfsberg Group is pleased to provide feedback to the Financial Action Task Force on the proposed revisions to Recommendation 16 and its Interpretative Note. The payments industry has evolved significantly since these guidelines were first issued and we welcome the initiative to update them. We believe that ‘a payment is a payment’ and that any entity, regardless of how it is described or refers to itself, should be subject to R.16 in line with the principle of ‘same activity, same risk, same rule’. In our response we highlight the importance of future proofing the Recommendation by adopting ISO20022 terminology, of the vitally important role that operators of payment market infrastructure (PMIs) have to play because, quite simply, if mandated information cannot fit into a message, then either that PMI must build the capacity to handle the information or it should not permit activity that requires such information to use it. Our response also highlights the importance of using the right tool for the job at hand and not to try and use R.16 for controls that would be addressed more appropriately by R.10 on customer due diligence.
Read morePublication of the CBDDQ and FCCQ’s Guidance materials in Spanish
We are pleased to announce that the CBDDQ and FCCQ’s Guidance materials (FAQs, Glossary and Guidance) have been translated into Spanish to widen their accessibility. Where a perceived difference exists between the English language original and the translation, the English language version prevails. Nos complace anunciar que los materiales orientativos (las Preguntas frecuentes o FAQ, el Glosario y la Guía) del Cuestionario de Diligencia Debida para Banca Corresponsal (CBDDQ por sus siglas en inglés) y del Cuestionario de Cumplimiento de Crimen Financiero (FCCQ por sus siglas en inglés) han sido traducidos al español para ampliar su accesibilidad. Cuando se perciba una diferencia entre el original en inglés y la traducción, prevalecerá la versión en inglés.
Read moreWolfsberg Group Principles for Auditing for Effectiveness
In 2019, the Wolfsberg Group (the Group) published a Statement on Effectiveness that included three ‘Wolfsberg Factors’ that we believe should underpin any financial institution’s Anti-Money Laundering/Counter Terrorist Financing (AML/CFT) programme. The Group has continued to build on the Wolfsberg Factors in subsequent publications. The Group believes that Internal Audit can assist their financial institutions in the fight against financial crime by measuring Financial Crime Risk Management outcomes using the Wolfsberg Factors and has developed these Principles for Auditing a Financial Crime Risk Management Programme for Effectiveness under the Wolfsberg Factors. In considering these Principles Internal Audit will not only promote effective Financial Crime Risk Management within financial institutions, but equally support how supervisors may also seek to assess the effectiveness of their regulated entities and the industry as a whole. This was as a joint exercise between member banks’ second and third lines of defence, to provide financial institutions with a framework for such an assessment.
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