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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

0 Years established
0Member banks
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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 Group Payment Transparency Standards

2023
English

Wolfsberg Group Response to HMT Consultation on UK AML/CTF Supervisory Regime

2023
English

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

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News

Wolfsberg Academy 2023

The 2023 Wolfsberg Academy took place last week and featured enriching discussions on Effectiveness, De-Risking and Financial Inclusion, Payment Transparency, Human Trafficking, Virtual Assets, Sanctions and Sanctions Evasion, Complex Investigations, and Technology. We thank the Faculty for their time and hard work, all participants for their enthusiasm and productive contributions, and the UBS Center for Education and Dialogue in Wolfsberg (Switzerland) for their hospitality.

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Publication of the updated Wolfsberg Group Payment Transparency Standards

Payment transparency can seem a very dry subject, but it is essential to the smooth functioning of the commercial world. Transparency is necessary, for example, to allow recipients to be able to apply incoming funds appropriately. Transparency is equally as important to managing financial crime risk, as it allows the screening of payments against sanctions lists and makes possible the process of transaction monitoring to identify unusual or suspicious activity, as required by law. If information about the transacting parties and the purpose of the payment are absent or incomplete, financial crime compliance processes will be made less effective and result in more friction, increased delays, and higher costs for all in processing payments. Ensuring minimum levels of transparency and providing clarity about where these responsibilities lie is thus of great importance to all payment service providers. This challenge has grown greater as payment innovation has resulted in new ways of moving funds. There is more widespread use of bundling of payments (the aggregation of more than one payment into a single transfer that may also be referred to as batch, bulk, or netting), as well as an increase in the number of and types of payment service providers (e.g. banks, MSBs, third party payment processors or TPPPs, fintechs, etc.). Moreover, value and the information about that value (i.e. details of underlying bundled payments) may not move in the same message or through the same channels. This subject has become more complex and nuanced since 2017, when the Wolfsberg Group published its Payment Transparency Standards. Therefore, today we are pleased to be publishing updated Payment Transparency Standards that: · Broaden coverage from financial institutions to all types of payment service providers and use the ISO 20022 terms. · Expand the list of stakeholders to include payment market infrastructures and competent authorities, who we believe should be involved in defining how their systems should (and should not) be used. · Affirm that all payments should be treated equally regardless of the type of entity processing them, and that the entity initiating the payment flow should have the primary obligation to ensure transparency. · Address the fact that certain intermediaries in the payment flow, by nature of the limited information they see in the normal course of business, should not be held accountable for the transparency and compliance obligations of the entity initiating the flow. · Provide illustrated examples of real-world payment chains highlighting their inherent transparency challenges. We hope these updated Standards serve to enhance the understanding of this subject, provide practical guidance to payment service providers, and help inform the dialogue on the roles and responsibilities of all relevant stakeholders.

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Publication of the Wolfsberg Group Response to HMT Consultation on UK AML/CTF Supervisory Regime

On 29 September 2023, The Wolfsberg Group submitted its response to HM Treasury's public consultation on the Reform of the UK Anti-Money Laundering and Counter-Terrorist Financing (AML/CTF) Supervisory Regime. Of the four models for reform outlined by HM Treasury, we believe that a public body Single Professional Services Supervisor (SPSS), i.e. ‘Model 3’, is best suited to address inconsistencies and systemic weaknesses in supervision, as it would: a. Enhance information sharing, public-private partnerships, and a focus on national threat priorities; b. Promote risk-based and outcome-based supervision; c. Ensure dissuasive sanctions; d. Support cross-cutting government policies. The Group also recommends that consideration is given to transitioning the supervision of higher-risk sectors, as identified by the UK’s National Risk Assessment, from HM Revenue & Customs to the Financial Conduct Authority. We are grateful for the opportunity to comment on the proposal and welcome dialogue with HM Treasury on enhancing the effectiveness of the UK’s supervisory and sanctions regimes.

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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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