Yesterday, the Wolfsberg Group published its long awaited Correspondent Banking Due Diligence Guidance. While we applaud the efforts of Wolfsberg, we also advise financial institutions to quickly review the guidance to determine what amendments policies, procedures, and program integration are necessary to align with this standard.
A&M’s Financial Crimes Team is well prepared to assist with this endeavor. Call one of our practice leads Hal Crawford or Larry Iwanski to discuss in detail.
The Wolfsberg Group is pleased to announce the publication of the updated Correspondent Banking Due Diligence Questionnaire (CBDDQ) and related guidance material (Completion Guidance, Frequently Asked Questions (FAQs) and Glossary). The CBDDQ aims to set an enhanced and reasonable standard for cross-border and/or other higher risk Correspondent Banking Due Diligence, reducing to a minimum any additional data requirements, as per the Wolfsberg definition and current FATF Guidance. It is also the Group’s expectation that the Group members will begin to use the CBDDQ, in a phased approach, with all of their respondents.
