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Anti-money laundering

Wolfsberg Group Updates Correspondent Banking Due Diligence Questionnaire

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.”

Islamic Banking & Finance

Dana Gas Sukuk Governing Law and Jurisdiction

This post discusses these issues in Dana Gas sukuk matter and offers some observations and lessons that can be drawn from the governing law and forum selection questions raised by the Dana Gas sukuk matter. As this post entails post hoc discussion of the Dana Gas sukuk offering based on publicly available information, there is an element (or more) of Monday morning quarterbacking, and this should be borne in mind. Nevertheless, the general observations and potential lessons—which are not unique to the Dana Gas sukuk or Islamic transactions—should be read for their generality.

Critical Resources

Guidance for Responsible Agricultural Supply Chains

This update briefly discusses aspects of the FAO-OECD Guidance for Responsible Investment in Agricultural Supply Chains (the “Guidance”), which is open for public comment through February 20, 2015. Among other things, the Guidance proposes a risk-based due diligence approach for adoption by enterprises engaged in the agricultural supply chain. Elements of the risk-based due diligence approach are outlined (with some comment) below, followed by considerations for sovereign and private investors, food-agri companies, and finance providers (e.g., commercial banks).

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