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 February 10, 2023, the Wolfsberg Group updated the Correspondent Banking Due Diligence Questionnaire (CBDDQ). Key updates to the CBDDQ V 1.4 include:
- a new section on Fraud (questions 127 through 132);
- additional questions related to Whistleblower Policy (question # 27), Virtual Bank License (question #9), the approval of Sanctions Policy (questions #24); and
- other changes designed to improve the logic, usability and flow of the questionnaire.
The Group expectation is that Group members will begin use of the updated CBDDQ in a phased approach with their respondents.
Concurrent with this release, and consistent with the changes made to the CBDDQ, the Group has also updated the Financial Crime Compliance Questionnaire (FCCQ) V 1.2 which is designed as a shorter version of the CBDDQ containing a basic set of questions for other customer type due diligence scenarios.