CBDDQ Statement, Dec 2017

The Wolfsberg Group wishes to provide an update with respect to its work on Correspondent Banking and the release, in October 2017, of the revised Due Diligence Questionnaire (DDQ) to the banking community.

As a result of our own conversations and feedback we have had from industry organisations, particularly in parts of the world where many banks have been "de-risked," the Group has decided that it should only publish the DDQ more widely once an additional set of materials has been completed. This is in order to limit the ability of third parties to interpret what it is that the Group intended with the DDQ and who it was directed to. These additional materials will include updated publication guidance (who this applies to, reasons for doing it, expectations for implementation); completion guidance (a question by question explanation of what each question means and how to respond to it); FAQs (questions we have already received and think are important for people to understand the answers to) and a glossary (consistent terminology so people don't interpret inappropriately/incorrectly and so FIs have the same baseline of understanding on e.g. products).

The Group has also decided to extract the 37 Standard questions (which replaced the 28 questions from the original questionnaire) from the new version and issue this as a stand-alone replacement for the existing DDQ. In so doing we are acknowledging that the original questionnaire was used far more broadly than simply for correspondent banking due diligence, however, the Group will not be issuing any recommendations as to which customer types it could be used for.

We intend to release all of these documents, along with the DDQ itself, in February 2018. In so doing, we are seeking to avoid circulation of differing interpretations that could arise should we, as the issuing Group of the DDQ, not clearly articulate what we intended, what is meant by the questions, what is desired with respect to answers, our expectations that it will take time for many organisations to reach that standard in the higher risk CB space and what we mean by the terminology employed.

Pending the release of the above, the DDQ can still be obtained by the banking community by contacting the Wolfsberg Group Secretariat at a dedicated address: ddq@wolfsberg-principles.com