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Wolfsberg updates ABC guidelines

Chris Hamblin, Editor, London, 17 July 2017

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The Wolfsberg Group has published a new set of guidelines to help financial institutions fight bribery and corruption and is conducting a major overhaul of its correspondent banking questionaire for the first time since 2004.

The "Anti-Bribery and Corruption [ABC] Compliance Programme Guidance" is an update of the anti-money-laundering banking club's the "Anti-Corruption Guidance" paper of 2011 and, as before, has been developed in collaboration with the Basel Institute of Governance and in consultation with Transparency International, whose founder, Jeremy Pope, was offered the leadership of the Financial Action Task Force when the world's Western powers set it up in 1989.

The document is designed to advise the broader financial services industry about how to develop, implement and maintain an effective ABC "compliance programme" - an American term for a firm's continuing compliance effort. The paper's primary objective is to promote a culture of ethical business practices at firms and also to help them obey their countries ABC laws and regulations. Wolfsberg recently published guidelines concerning politically exposed persons (PEPs) as well.

The group is also in the process of revising its "Due Diligence Questionnaire" for correspondent banks. The current questionnaire (consisting of 27 questions) dates from 2004. It has since remained largely unchanged, barring minor edits and the inclusion of an additional question in 2014. The group says that it is "no longer fit for purpose as a means of approaching due diligence requirements...due to dramatically changed and enhanced regulatory requirements and expectations." It believes that most private banks still use it but add their own questions to it also. The questionaire will be out sometime during this summer.

The members of the Wolfsberg Group, who formed it in the spirit of self-regulation, are private banks such as Banco Santander, Bank of America, Bank of Tokyo-Mitsubishi, Barclays, Citigroup, Credit Suisse, Deutsche Bank, Goldman Sachs, HSBC, JP Morgan Chase, Societe Generale, Standard Chartered, and UBS. Wolfsberg is a Swiss settlement that houses UBS's training facility.

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