Proportionality. Prioritisation. Effectiveness.

We released our first guidance at the Wolfsberg Group on the risk-based approach back in 2006, almost 20 years ago. Since that time, we have published various documents and FAQs that all touch on the application of the RBA. But we continue to listen to how fear limits the ambitions of regulators, law enforcement, and us in private sector in truly applying a risk-based approach. We applaud the FATF for highlighting, as part of their Rec 1 reforms and their recently released Guidance on Financial Inclusion, that we must reject a “zero failure” approach to financial crime compliance.

The Wolfsberg Group has made great gains over the first half of 2025 in working quietly among the members, as well as with key competent authorities, international organisations, civil society groups and other financial institutions around the world to further embed the RBA through practical, tangible activities that demonstrate proportionality, prioritisation, and effectiveness. We are not there yet, but the momentum is strong.

This statement re-establishes our commitment to the RBA. It includes a pledge to update our 2006 RBA guidance, along with other documents that touch on the risk-based approach, such as our 2015 FAQs on risk assessments, to press all of us to make those hard decisions on the “means” in order to get to the right “ends”. The focus must be on outcomes!

You can access the statement on our publications page: https://wolfsberg-group.org/resources/203