Global Standards
Who we are
The Wolfsberg Group is an association of 13 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
CBDDQ/FCCQ FAQs V3.0
CBDDQ Glossary v3.0
CBDDQ Guidance v2.0
FCCQ (Excel)
FCCQ (PDF)
CBDDQ (Excel)
CBDDQ (PDF)
The Wolfsberg Group Response to CPMI Consultation on ISO 20022 Harmonisation Requirements for Cross-Border Payments 2023
News
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://www.wolfsberg-principles.com/sites/default/files/wb/ISO%2020022%20Harmonisation%20Consultation%20-%20Wolfsberg%20Group.pdf).
Read morePublication 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
Read morePublication 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. The two translations are now available on the Wolfsberg Group website. 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。
Read moreThe Wolfsberg Group members elect Carolina Garces as Co-Chair of the Group
The Wolfsberg Group Secretariat is pleased to announce that the primary delegates of the Wolfsberg Group member banks have elected Carolina Garces, Global Head of Financial Crime Compliance for Santander, as the new Co-Chair of the Group. She replaces David Howes, Global Head of Financial Crime Compliance for Standard Chartered, whose term finished at the end of 2022. Ms. Garces will serve as Co-Chair with existing Co-Chair William Langford, MUFG Bank Global Head of Financial Crimes Compliance and Chief Compliance Officer for the Americas. The Wolfsberg Secretariat thanks Mr. Howes for the significant accomplishments under his role as Co-Chair. Ms. Garces’ term as Co-Chair runs from January 1, 2023 through to the end of 2024. Ms. Garces joined Santander in 2019, having previously held senior roles at multinational financial institutions such as HSBC, Goldman Sachs, BlackRock, and RBS. She also serves as a member of the Executive AML/CFT Committee of the European Banking Federation.
Read morePublication of the CBDDQ, FCCQ, Guidance, Glossary and FAQs
The Wolfsberg Group is pleased to announce the release of version 1.4 of the Correspondent Banking Due Diligence Questionnaire (CBDDQ) and version 1.2 of the Financial Crime Compliance Questionnaire (FCCQ), along with updated supporting Guidance, Glossary and FAQs documents. The CBDDQ updates include a new section on Fraud and additional questions related to Whistleblower Policy, Virtual Bank License, the approval of Sanctions Policy, and other changes designed to improve the logic, usability and flow of the questionnaire. The Declaration Statement has been updated to include a revised period for update of the Questionnaire. Commensurate changes were made to the FCCQ to ensure consistency with CBDDQ v1.4. The previously issued Completion Guidance and Capacity Building Guidance have been combined into a single guidance document, which highlights the potential risk addressed by questions and considerations the Respondent should make while responding to the question. Guidance notes are also provided for those questions where further explanation or definition would serve to aid readers’ understanding. The FAQ and Glossary documents have also been updated to address changes in the Questionnaires. Of note in the FAQs, the recommended timeframe for update of the Questionnaires has been adjusted to 12-18 months. This change addresses concerns of perceived expiration date of the questionnaire on a specific date which can cause delays when this date does not align with CDD review period. You can access the Questionnaires and all Guidance materials [here](wolfsberg-group.com/resources)
Read morePublication of the Wolfsberg Group and IIF Comment Letter to EBA on de-risking
On 6 February, the Wolfsberg Group and Institute of International Finance submitted comments via email and online in response to the EBA’s public consultation on ‘de-risking’ announced on December 6. The joint comments highlight the importance of alignment with the FATF definition of ‘de-risking’, that financial institutions should have the ability to apply a risk based approach to non for profit organisations (NPOs) in line with FATF Recommendation 8, recognition that have their own role in understanding the risks that they face and finally that commercial and risk management decisions also factor into financial institutions’ decisions on providing/maintaining banking services to customers.
Read morePublication of the Wolfsberg Principles for Using Artificial Intelligence and Machine Learning in Financial Crime Compliance
Artificial Intelligence and Machine Learning (AI/ML) can have, and are already having, a significant impact on improving the effectiveness and efficiency of financial crime compliance and risk management programmes. The Wolfsberg Group supports the leveraging of AI/ML by Financial Institutions to detect, investigate, and manage the risk of financial crime, as long as appropriate data ethics principles inform the use of these technologies to ensure fair, effective, and explainable outcomes. For this reason, today the Group is publishing its Principles for Using Artificial Intelligence and Machine Learning in Financial Crime Compliance. The document identifies five elements that support an ethical and responsible use of AI/ML: i. Legitimate Purpose; ii. Proportionate Use; Design and Technical Expertise; iii. Accountability and Oversight; iv. Openness and v. Transparency.
Read morePublication of the Wolfsberg Group Comment Letter on the EU AML/CFT Legislative Package
The Wolfsberg Group is pleased to share the Comment Letter on the EU AML/CFT Legislative Package that we addressed to key EU officials on October 28, 2022. The Group welcomes and supports the ambitious proposals to strengthen and harmonise the EU’s AML/CFT framework and regulatory oversight process. In the context of ongoing trialogue negotiations, the aim of our letter is to provide suggestions and observations on the following key issues: i. Harmonisation of supervisory practices and standards; ii. Enhanced information-sharing in line with GDPR principles; iii. Facilitating an effective risk-based approach. The content of the Group’s submission is in line with individual responses contributed by our 13 members, who have also engaged on the EU AML/CFT Legislative Package with trade associations and international bodies.
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