There are various entities involved in the prevention of money laundering and terrorist financing. From intergovernmental organizations like the FATF, to obliged entities responsible for applying preventive measures, and supervisory bodies such as the European Banking Authority. Among the wide range of participants in the prevention process, today we want to examine The Wolfsberg Group.
The Wolfsberg Group is a non-governmental association made up of 13 international banks. Its goal is to develop frameworks and guidelines for financial institutions on preventing money laundering, know your customer (KYC) practices, and terrorist financing. The group is named “Wolfsberg” after the castle in northeastern Switzerland where the first meeting took place on October 10, 1993, and continues to host their annual gatherings.
Currently, the banks that make up this group are:
- Banco Santander (Spain)
- Bank of America (USA)
- Barclays (UK)
- Citigroup (USA)
- Credit Suisse (Switzerland)
- Deutsche Bank (Germany)
- Goldman Sachs (USA)
- HSBC (UK)
- J.P. Morgan Chase (USA)
- MUFG Bank (Japan)
- Société Générale (France)
- Standard Chartered Bank (UK)
- UBS (Switzerland)
Actions
In October 2000, the “Wolfsberg Anti-Money Laundering Principles for Private Banking” were published, updated for the last time in 2012. This was the first initiative by the group, followed by other publications and recommendations on various issues related to preventing money laundering and terrorist financing over the years.
For example, their 2017 guidance on politically exposed persons (PEPs) highlights key criteria such as the definition of a PEP, the risks posed by such individuals, the relevant data when performing KYC on a PEP, and the necessity of using PEP databases to identify these types of clients.
In May 2022, the Wolfsberg Group published a document on frequently asked questions about negative news screening. The group emphasizes that using adverse news or other forms of negative information increases “the financial institution’s awareness of the potential financial crime risks posed by both current and potential clients.”
The Wolfsberg Group also publishes due diligence questionnaires for correspondent banking. These documents are designed to assist financial institutions in developing their due diligence processes regarding correspondent banking.
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