Publication of the Wolfsberg Financial Crime Principles for Correspondent Banking

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Treliant Takeaway:

Correspondent banks must develop and maintain financial crime compliance programs that adequately assess the financial institution’s overall risk profile, the risk of its customers and the financial crime compliance programs of its respondent customers. Our team at Treliant, which includes compliance professionals, ex-regulators, and auditors has deep experience in Anti-Money Laundering and Economic and Trade Sanctions in foreign and U.S. domestic correspondent financial institution program development, assurance and remediation, and is well positioned to help our clients to build risk-based, operationally effective and sustainable programs to respond to heightened regulatory scrutiny.


On October 28, 2022, the Wolfsberg Group updated the 2014 Wolfsberg Anti-Money Laundering Principles for Correspondent Banking and 2014 Correspondent Banking Principles FAQ documents, which are now superseded by the newly published Principles.

Key updates to the Principles include:

  • Definition of activity that presents the highest risks;
  • Explanation of the concept of a defined risk appetite for correspondent banking activity. Financial institutions should define an acceptable Board of Directors or executive management approved risk appetite which should identify prohibited or restricted party types and respondent bank account transactional activity which should be communicated internally and to the respondent’s customers; and
  • Factors to be considered during periodic review and ongoing management of correspondent banking relationships to assess whether the relationship remains within the financial institution’s risk appetite. Factors cited include: respondent bank geographic risk; providing correspondent banking relationships to branches, subsidiaries and affiliates; providing correspondent banking relationships to branches, subsidiaries and affiliates of other financial groups; respondent bank ownership and management structures; products and services offered by the respondent; the respondent bank’s customer base; products or services offered to the respondent bank; financial crime controls; no business arrangements with shell banks; and results of site visits.


Efren Marquez Alba

Efren Marquez Alba is an Engagement Director with Treliant. His financial crime experience includes Anti-Money Laundering/Counter-Terrorist Financing (AML/CFT), sanctions, anti-bribery and -corruption, and fraud. With Treliant, Efren has led independent assessments of compliance programs for adherence to the Bank Secrecy Act and Anti-Money Laundering rules (BSA/AML) and to the Office…