ResourcesPractical guidance and standards for financial crime risk management professionals

The Wolfsberg Group published one of the first known comprehensive private sector statements on the risk-based approach, dating back to 2006 in our Guidance on a Risk-Based Approach for Managing Money Laundering Risks. Since that time, we have continued to release guidance for the private sector on various elements of the risk-based approach in practice, and we continue to review and refine our views based on the experiences of our member banks and the evolution of their financial crime risk management programmes.

Our most recent statement on the risk-based approach coincides with the FATF's revisions to Recommendation 1. We see the risk-based approach as defined by:

• Proportionality: a financial institution should design and maintain a financial crime risk management programme proportionate to its business model as determined by its size, scale, footprint, customers and risk appetite (as informed by its assessment of risk).
• Prioritisation: a financial institution should prioritise attention on, and the allocation of resources to, higher risk customers and activities, which may also entail stopping, reducing, and/or redesigning existing activities that are determined to be redundant, duplicative, or unproductive from a risk management perspective.
• Effectiveness: a financial institution should focus on effective outcomes, as aligned to the Group's work on Demonstrating Effectiveness, facilitating a more responsive, forward-looking and dynamic approach to risk management, rather than applying a one-size-fits-all, rules-based approach.

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We are committed to developing a "common understanding of risk" between the public and private sectors. Our current publications are below, and we are currently in the process of updating our full library of related content, including for example: