The Wolfsberg Group has published a guidance paper looking at requests for information as used in AML transaction monitoring. RFIs are used when correspondents or other PSPs are looking to understand transactions that have been processed through an account or relationship in its books. That institution will make the request of the customer entity that sent the payment instruction.
The Wolfsberg Group comments that the RFI is a powerful tool which, properly used, allows a Correspondent to see how the Respondent’s AML/KYC programme works in practice. The Correspondent can also draw conclusions from the speed of response, and receipt of requests may prompt Respondents to consider their own assessment of the customer’s risk profile.
The guidance looks at the benefit and value of RFIs and the drivers for them. It then sets out roles and responsibilities for Correspondent and Respondents including appropriate questions, timelines and expectations, and what Correspondents should do in the case of insufficient or no response.