The Wolfsberg Group has published a statement on steps financial institutions can take to evolve their AML./CTF regimes to meet the key elements of the Wolfsberg effective programme. It outlines the key steps as:
- assess risk in defined priority areas, using their jurisdiction’s national risk assessment;
- implement and enhance controls – assessing adequacy of controls in the areas it has identified as presenting the most risk;
- prioritise resources using a risk based approach;
- engage with law enforcement; and
- demonstrate programme effectiveness – through a range of MI measures.