Priority focus areasWhere the Wolfsberg Group prioritizes and allocates resources to resolve global challenges in disrupting financial crime.

Correspondent Banking and Payments

The Wolfsberg Group is recognized for its global role in promoting best practices and standards in the areas of correspondent banking and payments. Our work aims to improve transparency, efficiency, and risk management, fostering a safer and more resilient financial ecosystem.

One of Wolfsberg's key contributions to correspondent banking is the development of the CBDDQ (the Correspondent Banking Due Diligence Questionnaire) and the FCCQ (the Financial Crime Compliance Questionnaire). These questionnaires represent the global standard for due diligence between financial institutions in establishing a correspondent relationship. We complement the questionnaires with extensive guidance, a glossary, and FAQs to help financial institutions of all sizes around the world capture accurately the core components of their financial crime risk management and compliance framework.

CBDDQ
PDF
FCCQ
PDF

See Resources below for guidance, FAQs, the glossary, and Excel versions of the questionnaires.

Payments

Wolfsberg's work on payment transparency dates back to some of the earliest initiatives by the public and private sector to ensure information on the debtor and creditor behind each payment is clear. This clarity is a critical dependence for downstream controls on monitoring for suspicious activity and screening, and in facilitating the ability of law enforcement to conduct effective cross-border investigations.

Payment Transparency Standards
2023
Guidance on Payment Transparency - Roles and Responsibilities
2024

See Resources below for consultation responses associated with payment transparency.

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Effectiveness

We believe true financial crime risk management is not just about compliance; it is about delivering effective outcomes for law enforcement.

In late 2019, the Wolfsberg Group members gathered in Frankfurt to agree on a common definition of “effectiveness”:

  1. Comply with AML/CTF laws and regulations;
  2. Provide highly useful information to relevant government agencies in defined priority areas; and
  3. Establish a reasonable and risk-based set of controls to mitigate the risks of a financial institution being used to facilitate illicit activity.

Since that time, the Wolfsberg Group has continued to develop the key themes of “effectiveness” in greater detail, while working in parallel with regulatory authorities across the world to embrace an approach to supervision that places increasing focus on effective outcomes over technical compliance.

The core documents that outline and detail our views on effectiveness are as follows:

Statement on Effectiveness
2019
Developing an Effective AML/CTF Programme
2020
Demonstrating Effectiveness
2021
Effectiveness Through Collaboration
2022
Auditing for Effectiveness
2024

All of our work associated with effectiveness, including our formal responses to consultation requests, can be found below.

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Risk-Based Approach

The Wolfsberg Group published one of the first known comprehensive private sector statements on the risk-based approach, dating back to 2006 in our Guidance on a Risk-Based Approach for Managing Money Laundering Risks. Since that time, we have continued to release guidance for the private sector on various elements of the risk-based approach in practice, and we continue to review and refine our views based on the experiences of our member banks and the evolution of their financial crime risk management programmes.

Our most recent statement on the risk-based approach coincides with the FATF's revisions to Recommendation 1. We see the risk-based approach as defined by:

  • Proportionality: a financial institution should design and maintain a financial crime risk management programme proportionate to its business model as determined by its size, scale, footprint, customers and risk appetite (as informed by its assessment of risk).
  • Prioritisation: a financial institution should prioritise attention on, and the allocation of resources to, higher risk customers and activities, which may also entail stopping, reducing, and/or redesigning existing activities that are determined to be redundant, duplicative, or unproductive from a risk management perspective.
  • Effectiveness: a financial institution should focus on effective outcomes, as aligned to the Group's work on Demonstrating Effectiveness, facilitating a more responsive, forward-looking and dynamic approach to risk management, rather than applying a one-size-fits-all, rules-based approach.

Find the full details here:

Statement on the Risk-Based Approach
2025

We are committed to developing a "common understanding of risk" between the public and private sectors. Our current publications are below, and we are currently in the process of updating our full library of related content, including for example:

RBA Guidance
2006
FAQs on Risk Assessments
2015
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Innovation

The Wolfsberg Group develops standards and best practices to foster responsible innovation, including the incorporation of artificial intelligence.

We believe that responsible innovation requires a careful, risk-based approach that integrates new technologies thoughtfully into existing frameworks.

Our work focuses on the application of innovative practices across financial crime controls. This includes, for example, the risk management of non-face-to-face customer relationships in the digital age, and the integration of machine learning into automated platforms for monitoring for suspicious activity, including for both supervised and unsupervised models. We are also increasingly focused on generative artificial intelligence (GenAI), and the journey in moving responsibly from generative to agentic AI.

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Digital Assets

The Wolfsberg Group actively develops guidance and standards to navigate the risks and opportunities associated with digital assets, including stablecoins.

Our focus is on defining “reasonable and risk-based controls” that recognize the distinct roles and responsibilities of the bank and the virtual asset service provider (VASP) when the two enter into a commercial relationship, including being clear on where those roles and responsibilities in financial crime risk management and compliance should begin and end.

As a Group, we also work to break down the cultural silos between financial crime investigators from traditional financial institutions and the VASPs, promoting enhanced private-to-private information sharing to be more effective is recovering funds for victims and disrupting financial crime for law enforcement.

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