Publication of the Wolfsberg Financial Crime Principles for Correspondent Banking

Today the Wolfsberg Group is publishing its updated Financial Crime Principles for Correspondent Banking. This document updates the 2014 version and provides guidance and best practices for banks, draws a distinction between Correspondent Relationships and Correspondent Banking activity, addresses entities other than banks who have Correspondent Relationships, and incorporates revised Frequently Asked Questions that were previously a separate document.

The Principles detail risk-based due diligence measures that, when undertaken, allow the Correspondent Bank to assess the profile, customer base and Financial Crime Programme of its Respondent customers. These Principles will assist Correspondent Banks in developing a programme that includes a fulsome assessment of the risks presented in Correspondent Banking relationships and will enable a comprehensive review of those risks as they apply to the Respondent Banks. For Respondent Banks receiving services, the document provides an understanding of the expectations they may encounter when requesting a Correspondent Banking Relationship. The updated document defines the activity that presents the most risk and introduces the concept of a defined risk appetite for Correspondent Banking Activity. It also provides factors to be considered during the periodic review and ongoing management of Correspondent Banking Relationships to determine if the relationship continues to be within the risk appetite.