ResourcesPractical guidance and standards for financial crime risk management professionals

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:

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

Public consultations and comments

Wolfsberg Response to the FBAs’ Notice of Proposed Rulemaking for the AML Program Rule

2024
Public consultations and comments

Wolfsberg Response to the Consultation on FinCEN’s Notice of Proposed Rulemaking (NPRM) for the AML/CFT Program Rule

2024
Public consultations and comments

Wolfsberg Group Response to the UK's HMT Consultation on the MLRs

2024
Guidance, Principles, Statements and Standards

Wolfsberg Group Principles for Auditing for Effectiveness

2024
Public consultations and comments

Wolfsberg Group Response to HMT Consultation on UK AML/CTF Supervisory Regime

2023
Public consultations and comments

Wolfsberg Group Comment Letter on the EU AML/CFT Legislative Package 2022

2022
Guidance, Principles, Statements and Standards

The Wolfsberg Group Paper on Effectiveness Through Collaboration

2022
Guidance, Principles, Statements and Standards

The Wolfsberg Group statement on Demonstrating Effectiveness

2021
Public consultations and comments

The Wolfsberg Group statement on Developing an Effective AML/CTF Programme

2020
Guidance, Principles, Statements and Standards

The Wolfsberg Group statement on "Effectiveness"

2019