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AboutResourcesNews

The leading voice in banking committed to combatting financial crime
Global Banks,
Global Standards


WHO WE ARE

The Wolfsberg Group is an association of 13 global banks which aims to develop
frameworks and guidance for the management of financial crime risks.


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CONCRETE HANDS-ON GUIDANCE BY PRACTITIONERS,
FOR PRACTITIONERS

0 Years established
0Member banks
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Resources published


KEY AREAS OF WORK


WORKING GROUPS

We produce guidance and standards to support the industry and other stakeholders
in the management of financial crime risk.


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QUESTIONNAIRES

Our Correspondent Banking Due Diligence and Financial Crime Compliance
questionnaires set an enhanced and reasonable standard for cross-border and/or
other higher risk correspondent banking due diligence.


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ADVOCACY

We also work towards promoting cooperation between the private and the public
sectors in the fight against illicit financial activity.


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CBDDQ & FCCQ

Developed and published by the Wolfsberg Group, the Correspondent Banking Due
Diligence Questionnaire (CBDDQ) seeks to help Financial Institutions conducting
due diligence on Correspondent Banking relationships, as per regulatory
requirements and their own internal policies and procedures.

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RESOURCES


Statements and Public Comment Letters


THE WOLFSBERG GROUP RESPONSE TO CPMI CONSULTATION ON ISO 20022 HARMONISATION
REQUIREMENTS FOR CROSS-BORDER PAYMENTS 2023

2023

English
CBDDQ


CBDDQ AND FCCQ FAQS V3.0

2023

English
CBDDQ


CBDDQ GLOSSARY V3.0

2023

English
CBDDQ


CBDDQ GUIDANCE V2.0

2023

English
CBDDQ


FCCQ V1.2 (EXCEL)

2023

English
CBDDQ


FCCQ V1.2 (PDF)

2023

English
CBDDQ


CBDDQ V1.4 (EXCEL)

2023

English
CBDDQ


CBDDQ V1.4 (PDF)

2023

English


SEE ALL RESOURCES


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NEWS




PUBLICATION OF THE WOLFSBERG GROUP RESPONSE TO THE CPMI CONSULTATION ON ISO
20022 HARMONISATION REQUIREMENTS FOR CROSS-BORDER PAYMENTS

On 1 March 2023, the Bank for International Settlements’ Committee on Payments
and Market Infrastructures (CPMI) launched a consultative report on ISO 20022
harmonisation requirements for enhancing cross-border payments. The Wolfsberg
Group welcomes the opportunity to comment on the report and provide insight into
the questions concerning financial crime compliance risk in today’s highly
complex and intermediated payment landscape. You can read the Comment Letter
[here](https://www.wolfsberg-principles.com/sites/default/files/wb/ISO%2020022%20Harmonisation%20Consultation%20-%20Wolfsberg%20Group.pdf).


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PUBLICATION OF THE WOLFSBERG ABC GUIDANCE

Today the Wolfsberg Group is publishing its updated Anti-Bribery and Corruption
Compliance Programme Guidance. This document updates the 2017 version and it is
designed to promote a culture of ethical business practices and compliance with
ABC legal and regulatory requirements. The Guidance is a risk-based approach for
the adequate development and implementation of compliance programmes to prevent,
detect, and report acts of Bribery and Corruption and identifies areas of
elevated risk. While no ABC compliance programme can prevent or protect against
Bribery and Corruption risks completely, and there is no one-size-fits-all
solution, this guidance can help the industry mitigate Bribery and Corruption
risks by using elements including but not limited to: An applicable firm wide
ABC policy; Governance with roles and responsibilities and access to top
management; Periodic risk assessment to assess the nature and extent of the
Bribery and Corruption risks, the establishment of a controls environment
covering risks associated with anything of value, third party providers and
customer related transaction risks, investments and acquisitions; Training and
awareness including the sharing of lessons learned from internal and external
events for continuous evaluation of the compliance programme adequacy; and
Monitoring and testing for compliance with controls to identify failure to act
in a manner consistent with the financial institution’s business
principles/policies/codes of conduct/applicable laws or regulations. The
Guidance incorporates learnings from enforcement actions since 2017 with updates
to the red flags section and expands the section on customer and transaction
corruption risks. The document includes the need for financial institutions’
programmes to be continuously evolving, and a new section on identifying,
reporting, and mitigating emerging Bribery and Corruption risks. Finally, the
guidance has been aligned to current and evolving legal regulatory expectations
with additional guidance for post-acquisition due diligence, the inclusion of
guidance for financial institutions to include a holistic risk assessment and
management as part of their control frameworks


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PUBLICATION OF THE NEGATIVE NEWS FAQS IN SIMPLIFIED CHINESE AND TRADITIONAL
CHINESE

The Wolfsberg Group is pleased to announce that the Negative News FAQs has been
translated into Simplified Chinese and Traditional Chinese. The two translations
are now available on the Wolfsberg Group website. Where a perceived difference
exists between the English language original and this translation, the English
language version prevails.
沃尔夫斯堡组织很荣幸的发布公告，日前其官方网站已提供“负面新闻常见问答解答”的简体中文翻译版和繁体中文翻译版。该“负面新闻常见问答解答”内容以英文版本为准，
中文翻译仅供参考。 沃爾夫斯堡組織很榮幸的發佈公告，
日前其官方網站已提供「負面新聞常見問答解答」的簡體中文翻譯版和繁體中文翻譯版。該等「負面新聞常見問答解答」內容以英文版本為準， 中文翻譯僅供參考。


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THE WOLFSBERG GROUP MEMBERS ELECT CAROLINA GARCES AS CO-CHAIR OF THE GROUP

The Wolfsberg Group Secretariat is pleased to announce that the primary
delegates of the Wolfsberg Group member banks have elected Carolina Garces,
Global Head of Financial Crime Compliance for Santander, as the new Co-Chair of
the Group. She replaces David Howes, Global Head of Financial Crime Compliance
for Standard Chartered, whose term finished at the end of 2022. Ms. Garces will
serve as Co-Chair with existing Co-Chair William Langford, MUFG Bank Global Head
of Financial Crimes Compliance and Chief Compliance Officer for the Americas.
The Wolfsberg Secretariat thanks Mr. Howes for the significant accomplishments
under his role as Co-Chair. Ms. Garces’ term as Co-Chair runs from January 1,
2023 through to the end of 2024. Ms. Garces joined Santander in 2019, having
previously held senior roles at multinational financial institutions such as
HSBC, Goldman Sachs, BlackRock, and RBS. She also serves as a member of the
Executive AML/CFT Committee of the European Banking Federation.


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PUBLICATION OF THE CBDDQ, FCCQ, GUIDANCE, GLOSSARY AND FAQS

The Wolfsberg Group is pleased to announce the release of version 1.4 of the
Correspondent Banking Due Diligence Questionnaire (CBDDQ) and version 1.2 of the
Financial Crime Compliance Questionnaire (FCCQ), along with updated supporting
Guidance, Glossary and FAQs documents. The CBDDQ updates include a new section
on Fraud and additional questions related to Whistleblower Policy, Virtual Bank
License, the approval of Sanctions Policy, and other changes designed to improve
the logic, usability and flow of the questionnaire. The Declaration Statement
has been updated to include a revised period for update of the Questionnaire.
Commensurate changes were made to the FCCQ to ensure consistency with CBDDQ
v1.4. The previously issued Completion Guidance and Capacity Building Guidance
have been combined into a single guidance document, which highlights the
potential risk addressed by questions and considerations the Respondent should
make while responding to the question. Guidance notes are also provided for
those questions where further explanation or definition would serve to aid
readers’ understanding. The FAQ and Glossary documents have also been updated to
address changes in the Questionnaires. Of note in the FAQs, the recommended
timeframe for update of the Questionnaires has been adjusted to 12-18 months.
This change addresses concerns of perceived expiration date of the questionnaire
on a specific date which can cause delays when this date does not align with CDD
review period. You can access the Questionnaires and all Guidance materials
[here](wolfsberg-group.com/resources)


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PUBLICATION OF THE WOLFSBERG GROUP AND IIF COMMENT LETTER TO EBA ON DE-RISKING

On 6 February, the Wolfsberg Group and Institute of International Finance
submitted comments via email and online in response to the EBA’s public
consultation on ‘de-risking’ announced on December 6. The joint comments
highlight the importance of alignment with the FATF definition of ‘de-risking’,
that financial institutions should have the ability to apply a risk based
approach to non for profit organisations (NPOs) in line with FATF Recommendation
8, recognition that have their own role in understanding the risks that they
face and finally that commercial and risk management decisions also factor into
financial institutions’ decisions on providing/maintaining banking services to
customers.


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PUBLICATION OF THE WOLFSBERG PRINCIPLES FOR USING ARTIFICIAL INTELLIGENCE AND
MACHINE LEARNING IN FINANCIAL CRIME COMPLIANCE

Artificial Intelligence and Machine Learning (AI/ML) can have, and are already
having, a significant impact on improving the effectiveness and efficiency of
financial crime compliance and risk management programmes. The Wolfsberg Group
supports the leveraging of AI/ML by Financial Institutions to detect,
investigate, and manage the risk of financial crime, as long as appropriate data
ethics principles inform the use of these technologies to ensure fair,
effective, and explainable outcomes. For this reason, today the Group is
publishing its Principles for Using Artificial Intelligence and Machine Learning
in Financial Crime Compliance. The document identifies five elements that
support an ethical and responsible use of AI/ML: i. Legitimate Purpose; ii.
Proportionate Use; Design and Technical Expertise; iii. Accountability and
Oversight; iv. Openness and v. Transparency.


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PUBLICATION OF THE WOLFSBERG GROUP COMMENT LETTER ON THE EU AML/CFT LEGISLATIVE
PACKAGE

The Wolfsberg Group is pleased to share the Comment Letter on the EU AML/CFT
Legislative Package that we addressed to key EU officials on October 28, 2022.
The Group welcomes and supports the ambitious proposals to strengthen and
harmonise the EU’s AML/CFT framework and regulatory oversight process. In the
context of ongoing trialogue negotiations, the aim of our letter is to provide
suggestions and observations on the following key issues: i. Harmonisation of
supervisory practices and standards; ii. Enhanced information-sharing in line
with GDPR principles; iii. Facilitating an effective risk-based approach. The
content of the Group’s submission is in line with individual responses
contributed by our 13 members, who have also engaged on the EU AML/CFT
Legislative Package with trade associations and international bodies.


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