#21 The Wolfsberg Questionnaire: Compliance Theatre or Effective Due Diligence?
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Are we genuinely assessing financial crime or ticking a box?
Is the Wolfsberg Correspondent Banking Due Diligence Questionnaire genuinely helping to combat money laundering, or has it become another costly compliance exercise?
Dawn Pretorius challenges the value of the Wolfsberg Questionnaire and the many variations developed by banks and compliance officers around the world. Designed to assess the anti-money laundering, sanctions and financial crime controls of correspondent banking partners, these questionnaires include about 150 questions and require documentation updates and repeated exchanges of information.
But what does this process actually achieve?
Dawn questions why regulated financial institutions must repeatedly provide information about their licences, policies, procedures, training programmes and internal controls when information is already available through regulators and institutional websites. She explores the considerable administrative burden placed on compliance teams, particularly when banks and fintechs maintain relationships with numerous correspondent banking partners.
Knowing what controls a bank claims to have is not the same as knowing whether those controls actually work.
This episode asks an uncomfortable question for the global AML industry: are we genuinely assessing financial crime risk, or simply creating more paperwork to demonstrate that compliance has been performed?
Join Dawn as she challenges conventional correspondent banking due diligence and invites the industry to debate whether it is time to rethink the Wolfsberg Questionnaire.
The Laundromat — challenging conventional thinking about anti-money laundering and financial crime.
Is the Wolfsberg Correspondent Banking Due Diligence Questionnaire genuinely helping to combat money laundering, or has it become another costly compliance exercise?
Dawn Pretorius challenges the value of the Wolfsberg Questionnaire and the many variations developed by banks and compliance officers around the world. Designed to assess the anti-money laundering, sanctions and financial crime controls of correspondent banking partners, these questionnaires include about 150 questions and require documentation updates and repeated exchanges of information.
But what does this process actually achieve?
Dawn questions why regulated financial institutions must repeatedly provide information about their licences, policies, procedures, training programmes and internal controls when information is already available through regulators and institutional websites. She explores the considerable administrative burden placed on compliance teams, particularly when banks and fintechs maintain relationships with numerous correspondent banking partners.
Knowing what controls a bank claims to have is not the same as knowing whether those controls actually work.
This episode asks an uncomfortable question for the global AML industry: are we genuinely assessing financial crime risk, or simply creating more paperwork to demonstrate that compliance has been performed?
Join Dawn as she challenges conventional correspondent banking due diligence and invites the industry to debate whether it is time to rethink the Wolfsberg Questionnaire.
The Laundromat — challenging conventional thinking about anti-money laundering and financial crime.
