On 12 August 2020, the Wolfsberg Group published its statement on developing an effective anti-money laundering (AML) / counter-terrorism financing (CTF) programme.
In December 2019, the Wolfsberg Group published a statement on effectiveness which encourages jurisdictions to adopt the Financial Action Task Force’s focus on effective outcomes. As part of that statement, the Wolfsberg Group outlined what it believes are the key elements of an effective AML/CTF programme.
Since the publication of the statement, the Wolfsberg Group has been encouraged by the action taken in several jurisdictions to move towards more effectiveness-focused AML/CTF regimes. As policy makers and supervisors continue to develop their approach, the latest statement by the Wolfsberg Group sets out certain suggested steps that financial institutions could take to evolve their AML/CTF programmes. The suggested steps are set out under the following headings: assess risk in defined priority areas, implement/enhance controls, prioritise resources and engage with law enforcement.