The Wolfsberg Group’s Principles for Correspondent Banking questionnaire is a set of questions that financial institutions can use to assess the risk associated with establishing or maintaining a correspondent banking relationship. The questionnaire covers a range of topics, including the bank’s customer due diligence processes, anti-money laundering (AML) and counter-terrorist financing (CTF) policies, and risk management systems.
The purpose of the questionnaire is to help financial institutions identify and manage the risks associated with correspondent banking relationships and ensure compliance with relevant laws and regulations. It is intended to be used as a tool to assess the risk of a correspondent bank, rather than as a checklist of requirements that must be met.
[data:image/svg+xml,%3csvg%20xmlns=%27http://www.w3.org/2000/svg%27%20version=%271.1%27%20width=%2730%27%20height=%2730%27/%3e](data:image/svg+xml,%3csvg%20xmlns=%27http://www.w3.org/2000/svg%27%20version=%271.1%27%20width=%2730%27%20height=%2730%27/%3e)
- What is the nature of the bank’s business? This question aims to understand the types of products and services offered by the bank, as well as its primary lines of business. This information helps the correspondent bank understand the bank’s risk profile and how it might be impacted by the bank’s activities.
- What is the bank’s organizational structure and ownership? This question asks about the bank’s legal structure, ownership, and any affiliates or subsidiaries. Understanding the bank’s organizational structure can help the correspondent bank identify potential conflicts of interest or other issues that could affect the risk of the correspondent banking relationship.
- What is the bank’s customer base? This question asks about the types of customers served by the bank, including individual customers, small and medium-sized enterprises (SMEs), and large corporations. Knowing the bank’s customer base can help the correspondent bank understand the risks associated with different types of customers and the bank’s overall risk profile.
- What is the bank’s geographical focus? This question asks about the countries and regions where the bank operates and where its customers are located. Understanding the bank’s geographical focus can help the correspondent bank identify potential risk factors related to the bank’s operating environment, such as the level of economic development or the regulatory environment.
- What is the bank’s risk profile? This question asks about the bank’s overall risk profile, including its risk management systems and processes, as well as any regulatory or compliance issues that may have been identified. Understanding the bank’s risk profile can help the correspondent bank assess the potential risk of a correspondent banking relationship.
- How does the bank manage its risk? This question asks about the bank’s risk management systems and processes, including how it identifies, assesses, and mitigates risk. Understanding how the bank manages its risk can help the correspondent bank assess the bank’s ability to identify and address potential risks that could affect the correspondent banking relationship.
- What is the bank’s AML/CTF policy? This question asks about the bank’s policies and procedures for preventing money laundering and terrorist financing, including its customer due diligence processes, transaction monitoring systems, and suspicious activity reporting systems. Understanding the bank’s AML/CTF policy can help the correspondent bank assess the bank’s commitment to complying with relevant laws and regulations and the potential risk of a correspondent banking relationship.
- How does the bank conduct customer due diligence (CDD)? This question asks about the bank’s processes for identifying and verifying the identity of its customers, as well as its procedures for assessing the risk associated with different types of customers. Understanding the bank’s CDD processes can help the correspondent bank assess the bank’s ability to identify and mitigate potential risks associated with its customers.
- How does the bank monitor transactions? This question asks about the bank’s systems and processes for monitoring transactions for suspicious activity, including its use of transaction monitoring software and the training and resources provided to staff for this purpose. Understanding the bank’s transaction monitoring processes can help the correspondent bank assess the bank’s ability to identify and report suspicious activity.
- How does the bank handle suspicious activity reports (SARs)? This question asks about the bank’s procedures for submitting suspicious activity reports to the appropriate authorities and for following up on any issues that are identified. Understanding the bank’s SARs processes can help the correspondent bank assess the bank’s commitment to complying with relevant laws and regulations.
- What is the bank’s policy on Politically Exposed Persons (PEPs)? This question asks about the bank’s policies and procedures for identifying and assessing the risk associated with Politically Exposed Persons (PEPs), who are individuals who hold or have held positions of public trust and are therefore considered to be at higher risk for money laundering and corruption. Understanding the bank’s PEPs policy can help the correspondent bank assess the bank’s ability to identify and mitigate potential risks associated with PEPs.
- What is the bank’s policy on compliance with economic sanctions? This question asks about the bank’s policies and procedures for complying with economic sanctions, which are measures imposed by governments or international organizations to restrict trade or financial transactions with specific countries or individuals. Understanding the bank’s sanctions compliance policy can help the correspondent bank assess the bank’s commitment to complying with relevant laws and regulations.
- How does the bank handle complaints and disputes? This question asks about the bank’s procedures for handling customer complaints and disputes, including how it investigates and resolves any issues that are identified. Understanding the bank’s complaints and disputes process can help the correspondent bank assess the bank’s commitment to customer service and its ability to identify and address potential risks.
- How does the bank handle breaches of its AML/CTF policy? This question asks about the bank’s procedures for responding to and addressing breaches of its AML/CTF policy, including its process for reporting any breaches to the appropriate authorities. Understanding the bank’s breach response process can help the correspondent bank assess the bank’s commitment to complying with relevant laws and regulations and its ability to identify and address potential risks.
- How does the bank handle requests for information from regulatory authorities? This question asks about the bank’s procedures for responding to requests for information from regulatory authorities, including how it handles requests for customer information or transaction data. Understanding the bank’s process for responding to regulatory requests can help the correspondent bank assess the bank’s commitment to complying with relevant laws and regulations.
—
This page was last updated on January 3, 2023.
–