The Wolfsberg Group

Applying the Wolfsberg Correspondent Banking Due Diligence Questionnaire in Brazil   The Wolfsberg Group (the Group) has engaged with ABRACAM - Associação Brasileira de Câmbio (The Brazilian Foreign Exchange Association) to better understand their proposal to introduce a process to validate local institutions’ responses to the Wolfsberg Correspondent Banking Due Diligence Questionnaire (CBDDQ), with the validation performed by an independent auditing company. This initiative has seen Abracam working alongside other local entities, highlighting the CBDDQ's comprehensive coverage of the essential aspects of an obliged entity’s financial crime compliance control framework. A key part of this collaboration has been the promotion of high standards in the foreign exchange market through the assessment and certification of the obliged entity’s AML program, which can be enhanced by the application of the CBDDQ – a market segment outside the CBDDQ’s original design. To know more about this initiative, look at the news on our website: 👉 https://lnkd.in/eWdDRzQb

The Wolfsberg Group is pleased to announce that the Executive Summary of its Anti-Bribery and Corruption Compliance Programme Guidance published in 2023  is now available in Spanish.  You can find the link to the full document in the comments below.    🇪🇦 El Grupo Wolfsberg se complace en anunciar que el Resumen Ejecutivo de su Guía del Programa de Cumplimiento Antisoborno y Corrupción publicado en 2023 ya está disponible en español.  Puede encontrar el enlace al documento completo en los comentarios más abajo. 

The Wolfsberg Group has just published a Statement on Monitoring for Suspicious Activity in line with the Wolfsberg Factors from 2019. The paper can be read on our website (link in the comments). ✍ Note: the links which were not active in the previously published document now work. Big thanks to our attentive readers!

The Wolfsberg Group Group is delighted to publish a Statement on Monitoring for Suspicious Activity in line with the Wolfsberg Factors from 2019. The Group does not believe that the value being derived from the (constantly increasing) volume of SARs/STRs is contributing proportionately to effective outcomes in the fight against financial crime. While the concept of effectiveness has been discussed for many years by lawmakers, regulators, supervisors, standard setters as well as the private sector, the Group believes it has yet to be fully integrated into the overall FCRM framework which will require acceptance and alignment across public and private sectors. This paper seeks to describe how consideration of the Wolfsberg Factors can be translated into a more effective approach to Monitoring for Suspicious Activity (MSA). We have deliberately chosen to characterise this as MSA to cast a wider net than just Transaction Monitoring because customer behaviour and customer attributes, when combined with the consideration of transactions, can provide a broader insight into potentially suspicious activity. Transaction Monitoring is therefore a sub-set of MSA, which might also include concepts such as ongoing Customer Due Diligence (CDD). This paper encourages all parties to be proactive in the development of innovative techniques and supporting technologies which we believe will deliver more effective end-to end risk detection capabilities. The paper can be read below as well as on our website (link in the comments). #FCC #financialcrime

The Wolfsberg Group is pleased to announce the submission of its response to the UK’s HM Treasury consultation on improving the effectiveness of the Money Laundering Regulations 2017 (MLRs). This consultation is part of a broader initiative under the Economic Crime Plan 2023-26. Our response addresses two core themes of the consultation: making customer due diligence more proportionate and effective, and strengthening system coordination. We welcome the opportunity to contribute to these crucial discussions, aiming to increase the effectiveness and proportionality of the regulations for both regulated firms and their customers, thereby supporting the ongoing fight against economic crime. The paper can be read below as well as on our website (link in the comments).

The Wolfsberg Group Forum is a special event where the financial crime risk management community in both public and private sectors can meet to discuss how to enhance all of our approaches to combatting illicit activity. Thanks to all the supervisors, regulators, standard setters, NPOs and private sector participants who joined us and shared their wisdom, proposals and challenges. Big thanks to the Secretariat staff of Agnes Ciccarone, Anna Peyre, and Yulia Murat for their work on their first forum and to our co-chairs Joseph Salama and Jennifer Shasky Calvery

We just wrapped up the 2024 Wolfsberg Group Forum. Thank you to our industry leaders and practitioners for their participation and invaluable contributions in the domain of fighting financial crime!   Among the main topics discussed this year were:   - Prioritising the risk-based approach and effectiveness. Fighting financial crime is about tackling the biggest risks rather than creating or having to manage checklists!  - Payment transparency. The payments ecosystem is undergoing a profound change, and the Group is at the forefront of the latest developments. - Sanctions and export controls. The latest insight on typologies and circumvention techniques was shared, along with best practices on how to prevent and respond to those risks.  - Technology and innovation. Progress brings with it new opportunities and challenges, and new technologies are instrumental in fighting financial crime.   #WolfsbergGroup #FCC #financialcrime #riskmanagement #Sanctions #Leadership #innovation #compliance

The Wolfsberg Group is deeply saddened by the loss of Gretta Fenner. The Group and the Basel Institute on Governance have a relationship that goes back many years, and which became much deeper once the Group was established as a legal entity and established a physical presence in the Institute's offices. This co-location gave us the opportunity to get to know Gretta better and news of her death has been a blow to us all. We will miss her energy, drive, humour, and common-sense approach and send our deepest sympathies to her family and loved ones. Our thoughts are also with the staff and management at the Basel Institute on Governance who have lost a leader and a friend. https://lnkd.in/dwHUYATt

Payment transparency can seem a very dry subject, but it is essential to the smooth functioning of the commercial world. Transparency is necessary, for example, to allow recipients to be able to apply incoming funds appropriately. Transparency is equally as important to managing financial crime risk, as it allows the screening of payments against sanctions lists and makes possible the process of transaction monitoring to identify unusual or suspicious activity, as required by law. If information about the transacting parties and the purpose of the payment are absent or incomplete, financial crime compliance processes will be made less effective and result in more friction, increased delays, and higher costs for all in processing payments.   Ensuring minimum levels of transparency and providing clarity about where these responsibilities lie is thus of great importance to all payment service providers. This challenge has grown greater as payment innovation has resulted in new ways of moving funds. There is more widespread use of bundling of payments (the aggregation of more than one payment into a single transfer that may also be referred to as batch, bulk, or netting), as well as an increase in the number of and types of payment service providers (e.g. #banks, #MSBs, third party payment processors or #TPPPs, #fintechs, etc.). Moreover, value and the information about that value (i.e. details of underlying bundled payments) may not move in the same message or through the same channels. This subject has become more complex and nuanced since 2017, when The Wolfsberg Group published its Payment Transparency Standards. Therefore, today we are pleased to be publishing updated Payment Transparency Standards that: ·       Broaden coverage from financial institutions to all types of payment service providers and use the ISO 20022 terms. ·       Expand the list of stakeholders to include payment market infrastructures and competent authorities, who we believe should be involved in defining how their systems should (and should not) be used. ·       Affirm that all payments should be treated equally regardless of the type of entity processing them, and that the entity initiating the payment flow should have the primary obligation to ensure transparency. ·       Address the fact that certain intermediaries in the payment flow, by nature of the limited information they see in the normal course of business, should not be held accountable for the transparency and compliance obligations of the entity initiating the flow. ·       Provide illustrated examples of real-world payment chains highlighting their inherent transparency challenges.   We hope these updated Standards serve to enhance the understanding of this subject, provide practical guidance to payment service providers, and help inform the dialogue on the roles and responsibilities of all relevant stakeholders.   The paper can be read below as well as on our website (link in the comments).