Wolfsberg Group Releases Correspondent Banking Due Diligence Questionnaire, Related Guidance and FAQs

The Wolfsberg Group on February 22, 2018 published revised Correspondent Banking Due Diligence Questionnaire (CBDDQ), along with related guidance and FAQs. The CBDDQ and related materials are available at the Wolfsberg Group’s CBDDQ page.

As explained in an October 29, 2017 MassPoint post, the Wolfsberg Group first announced the release of the CBDDQ in 2017. However, the Group did not make the CBDDQ widely available. After initially announcing the CBDDQ, the Wolfsberg Group held back after deciding that the CBDDQ should be published more widely “once an additional set of materials has been completed . . .  in order to limit the ability of third parties to interpret what it is that the Group intended with the DDQ and who it was directed to.”

With the February 2018 revised CBDDQ, related guidance materials and FAQs, the Wolfsberg Group has provided the below statement.

“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.

In the long term, it is the Group’s view that the adoption of a standardised, reasonable CBDDQ should engender a less arduous, and thereby inherently less costly, due diligence process for Correspondent Banks, which, as it beds down, should also allow for a standard which all Financial Institutions, and their supervisors, can work towards achieving. This should, in the end, support the objectives of the G20 and other supranational organisations towards a well supervised and more harmonised regulatory standard in the correspondent banking space, with longer term positive effects on de-risking, access to finance, the development of trade and financial inclusion.

The Group is also conscious that its original questionnaire has been used in multiple other customer type due diligence scenarios and, therefore, while not seeking to prescribe how, or for which customer types, the questionnaire should be used, the Group has nonetheless issued the Wolfsberg Group Financial Crime Questionnaire (FCCQ) which is a shorter version of the CBDDQ and contains a basic set of questions to address Industry demand.”

Wolfsberg Group Statement

For more information about the CBDDQ, U.S. and international AML/CFT regulation , standards and compliance generally or in connection with correspondent banking, contact MassPoint PLLC at info@masspointpllc.com.