In 2019, the Wolfsberg Group (the Group) published a Statement on Effectiveness that included three ‘Wolfsberg Factors’ that we believe should underpin any financial institution’s Anti-Money Laundering/Counter Terrorist Financing (AML/CFT) programme. The Group has continued to build on the Wolfsberg Factors in subsequent publications.

The Group believes that Internal Audit can assist their financial institutions in the fight against financial crime by measuring Financial Crime Risk Management outcomes using the Wolfsberg Factors and has developed these Principles for Auditing a Financial Crime Risk Management Programme for Effectiveness under the Wolfsberg Factors. In considering these Principles Internal Audit will not only promote effective Financial Crime Risk Management within financial institutions, but equally support how supervisors may also seek to assess the effectiveness of their regulated entities and the industry as a whole. This was as a joint exercise between member banks’ second and third lines of defence, to provide financial institutions with a framework for such an assessment.