The Wolfsberg Group

Very pleased to report that a key message coming out of the #NoMoneyForTerror Ministerial Conference, in advance of the Munich Security Conference, was the need to bring supervisory bodies to the table to address our critical threat finance challenges collectively. Until examiners, the private sector, and the national FIUs come together to align on our priorities and incentivize and enforce those priorities, much of the most valuable work produced by financial institutions in providing valuable leads to law enforcement – while assuming the risk in responsibly addressing the unbanked – will continue to be underappreciated. As I said in my expert panel along with Elisa de Anda Madrazo of the Financial Action Task Force (FATF), Carolin Gardner of the European Banking Authority (EBA), and Lia van Broekhoven of the Human Security Collective, the mistake here is to blame the examiner for being “out of touch.” It is on us, as a collective, to ensure that examiners are more than a “part” of the conversation but rather a partner in the solution, and from the beginning. Thank you to Elisa de Anda Madrazo for carrying that message forward to the ministers, which she did with great enthusiasm this afternoon. The only way forward here is collective action. That is the legacy of The Wolfsberg Group as we move into our 25th anniversary, and that is the spirit that we will continue to carry forward.

The Wolfsberg Group elects a new Co-chair Emma Molvidson, the Global Head of Financial Crime Prevention for UBS, has been elected as the new Co-Chair of The Wolfsberg Group, effective from January 1, 2025.   Emma became the Global Head of Financial Crime Prevention at UBS in April 2023. She has held a variety of senior management roles at UBS over the past 14 years in Group Legal, the Investment Bank as well as leading Compliance & Investigations.   “Emma provides a unique perspective within Wolfsberg, given her legal and  investment bank background. I am thrilled to partner with her as co-chair and benefit from her experience as we continue to drive forward the effectiveness agenda of our member banks,” says Jennifer Shasky Calvery, current co-chair of the Group and Global Head of Financial Crime Risk and Compliance at HSBC.   Prior to joining UBS, Emma was at Swiss Re and she also has a private practice background in corporate finance from Norton Rose in London and Paris.   Emma succeeds Joseph Salama at Deutsche Bank. The Wolfsberg Group thanks Joe for his dedication and support over the years, both from his time as co-chair and also as a primary delegate to the Group. “Joe’s enthusiasm and optimism for reform has had an immeasurable, motivational impact on the Group’s membership, and he will be missed,” says J. Edward Conway, the Executive Secretary at Wolfsberg. “But in replacing Joe, Emma provides continuity as an inspiring voice on the management committee that can also draw on a deep experience in the role of general counsel.”  

The Wolfsberg Group has just published the German translation of its Statement on Monitoring for Suspicious Activity. You can read it below and on our website (see link in the comments). 🇩🇪 Die Wolfsberg-Gruppe hat soeben die deutsche Übersetzung ihrer Erklärung zur wirksamen Überwachung verdächtiger Aktivitäten veröffentlicht. Sie können sie unten und auf unserer Website lesen (siehe Link in den Kommentaren).

The Wolfsberg Group has just published its "Payment Transparency Roles & Responsibilities" guidance. Payments can flow in a variety of ways and involve many types of payment service providers, messaging systems and payment market infrastructures. This document provides an overview of the roles played by key actors in a payment chain. It also sets out their respective responsibilities to adhere to payment transparency standards across a sample of commonly observed payment flows and serves as a reference guide that can be used by all payment service providers, regulators, and standard setters. This guidance supplements, and should be read in conjunction with, the Wolfsberg Group Payment Transparency Standards published in October 2023. The guidance is available below and on our website (link in the comments).

Response of The Wolfsberg Group to FATF consultation on AML/CFT and Financial Inclusion - R1,10 and 15 The Wolfsberg Group agrees with the FATF’s goal to create an anti-money laundering/countering the financing of terrorism (“AML/CFT”) regulatory environment that reinforces the risk-based approach while also supporting financial inclusion. Requiring excessive AML/CFT measures that do not respond to the identified risks is inefficient and ineffective, while the unintended consequences of restricting under-served communities’ access to financial services decreases the reach and effectiveness of AML/CFT regimes. As noted in the Group’s original Statement on Effectiveness, an effective AML/CFT programme will “have the benefit of reducing friction on customers and helping governments with their objective of financial inclusion". You can find the text of our response below and on our website (link in the comments).

The Wolfsberg Group is looking for a policy advisor to join its team. If you're interested in the fight against financial crime, this position offers great exposure and opportunity for candidates with the right experience.

Agreeing on a common lexicon in the digital assets space continues to be a challenge. Today The Wolfsberg Group Group shares a collection of Frequently Asked Questions (FAQs) on Defining Digital Assets in an Emerging Financial Crime Compliance Risk Environment, which captures how the Group's members conceive of and conceptualise key terms associated with digital assets - in their engagement with policymakers, supervisors, regulators, and other FIs, and in developing their own policies and designing appropriate controls. These terms will serve as a reference going forward for subsequent work by the Group on the risks and associated controls for digital assets. The document is accessible below and on our website (link in the comments).

Publication de la version française des Normes de Transparence des Paiements du Groupe Wolfsberg (2023)     The Wolfsberg Group is pleased to announce the publication of the French version of its Payment Transparency Standards. Payment transparency can seem a very dry subject, but it is essential to the smooth functioning of the commercial world. Transparency is particularly 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. You can consult the French version of the Standards below and on our website (see links in the comments). 🇫🇷 The Wolfsberg Group est heureux d'annoncer la publication de la version française de ses Normes de transparence des paiements. La transparence des paiements peut sembler un sujet très aride, mais elle est essentielle au bon fonctionnement du monde commercial. La transparence est notamment importante pour la gestion du risque de criminalité financière, car elle permet de vérifier les paiements au regard des listes de sanctions et rend possible le processus de surveillance des transactions afin d'identifier les activités inhabituelles ou suspectes, comme l'exige la loi. Vous pouvez consulter les Normes ci-dessous et sur notre site web (voir liens dans les commentaires).

The Wolfsberg Group Group announces today the appointment of its next Executive Secretary, J. Edward 'Ned' Conway, effective November 1st. Ned was most recently the Group Head of Financial Crime Compliance Framework and Policies at Banco Santander. Alan Ketley will retire from his role as Executive Secretary since assuming the position in 2021. The members of the Wolfsberg Group are grateful for Alan’s leadership over an important period of transition for the Group and during a critical moment of regulatory reform across the US, UK and the EU. The full release and details are available on our website (link in the comments).

The Wolfsberg Group Group just completed its annual Academy in Wolfsberg/ Ermatingen (CH). 27 representatives from the 12 Group member banks and from 4 non-member banks, coming from Asia, UAE, the US and Europe, gathered to network and learn from each other and from experienced peers about key current and upcoming challenges faced by financial institutions in their fight against financial crime. Throughout a series of interactive sessions and case studies, participants discussed the risks linked to sanctions and sanctions circumvention, exchanged views on strategies for more effective payment transparency, and on new areas of interest such as digital assets and artificial intelligence and its long-term impact on the compliance officers and their business. 👉 The Wolfsberg Academy was launched in 2005 as an annual 3-day event at the Chateau Wolfsberg where promising candidates from the Group and also external banks share experiences and discuss FCC topics of current concern with senior experts from the member banks. Since inception, more than 400 aspiring young officers have attended these courses at the Academy which have since also been held outside Switzerland to widen the audience of future FCC officers and to share the spirit of the Wolfsberg Group.