February/March 2018 Update: The Wolfsberg Group has released the updated Correspondent Banking Due Diligence Questionnaire. Please see this more recent MassPoint Blog post for background and links.
Wolfsberg Group Correspondent Banking Due Diligence Questionnaire 2017
The Wolfsberg Group, a group of thirteen global banks, on October 15, 2017 announced its issuance of a “comprehensively” updated Correspondent Banking Due Diligence Questionnaire (the “CBDDQ”). The CBDDQ responds to FATF Recommendation 13 on Correspondent Banking and is the international correspondent banking standard on which the Wolfsberg Group members have “settled“, “committed to being early adopters of,” and plan to support “with FAQ’s and additional awareness raising materials.”
The Wolfsberg Group is making the CBDDQ available to the “banking community;” requests for the CBDDQ should be directed to the Wolfsberg Group Secretariat by email to firstname.lastname@example.org.
Key excerpts from the Wolfsberg Group statement on the CBDDQ are copied below. The full text is here.
Today the “CBDDQ” has been comprehensively updated, recognising that regulatory expectations have increased and industry practices have evolved. After a significant amount of discussion and exchange, the Group’s member Banks have settled on 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 be adopted over time across the industry, as was the first DDQ, and 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.
The CBDDQ comprises a comprehensive set of questions which Wolfsberg Group member banks, and most of its respondents, were familiar with as these were already being used as part of the respondent bank due diligence process. Now, however, these questions have been refined and formulated in a consistent way, as well as being better structured to cover all main aspects required to conduct effective correspondent banking due diligence. As such, the CBDDQ goes much further than either of the previous (2004 or 2014) versions which were adopted and utilised very much as a “minimum” question set. Instead the CBDDQ constitutes a “reasonable and enhanced” question set likely to be satisfactory in most situations, barring very exceptional cases.