On 17 April 2020, the Wolfsberg Group released an updated version of its Correspondent Banking Due Diligence Questionnaire (CBDDQ) and Financial Crimes Compliance Questionnaire (FCCQ) with changes focused on greater clarity and ease of use. The Wolfsberg Group has also updated the supporting FAQs, completion guidance and capacity building guidance.
The principal changes are:
- Questions CBDDQ ‘14’, ‘70’ and FCCQ ‘27’ were changed to refer to ‘non-resident’ rather than ‘offshore’ customers.
- Question CBDDQ ’77’ and FCCQ ‘31’ have been changed to refer to ‘suspicious activity’ rather than from ‘currency’ reporting.
- Question CBDDQ ‘94’ was removed and blanked out thus not changing the numbering of the following questions.
Various questions were updated so that responses are in a drop down format or additional options were added to provide more specific answers. Additionally, all guidance materials have been updated based on the changes to the questionnaires.