Posted by Stewart Wilkinson, Partner
The Banking Industry standards organisation, the Wolfsberg Group, made up of 13 leading banks, which aims to develop frameworks and guidance for the management of financial crime risks has issued new guidance on Anti-Bribery and Corruption (ABC) compliance for financial institutions. These form the current measure of best practice for banks and other financial services businesses.
The ABC Guidance is available on the Wolfsberg Group website here. It recommends taking a risk-based approach to the development of ABC programmes to combat corruption and emphasises the importance of internal reporting.
The appendix to the guidance gives useful examples of ‘red flags’ that banks should build into ABC programmes and which may require enhanced due diligence or review.
The Wolfsberg group has also, on 15 October 2017, completed two pieces of work to strengthen the international financial system. It has released a Correspondent Banking Due Diligence Questionnaire (CBDDQ) and a revised Payment Transparency Standard.
The CBDDQ is aimed at introducing one due diligence standard for international correspondent banking which is being made available to KYC utilities and the wider banking community. The Group hopes this will constitute the standard for KYC utilities, providing benefits to all banks, for which Correspondent Banking due diligence remains an important but complex, time consuming and costly exercise. Guidance on how the CBDDQ can be obtained can be found here.
The revised Payment Transparency Standard can be found here.
For more information on the Wolfsberg Group's guidance, please contact Stewart Wilkinson in our Banking & Finance team on:
020 78421 460 Email us
Our Financial Services lawyers understand your sector and are on hand to help.