The Wolfsberg Group has reminded of its suggestions for how financial institutions can have effective AL/CTF compliance programmes, and of its 2020 recommendations for ensuring effective outcomes. The reminder comes with a message that it is important to show that controls are effective. It says its factors are a useful tool towards this – where an institution can prove compliance for a specific threat or overall, it will be strong evidence of its effectiveness. The paper looks at
- compliance with law and regulation
- providing useful information to government authorities in priority areas and
- reasonable and risk based controls