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Wolfsberg Group Publishes New Risk-Based Approach Statement

25 July 2025

Wolfsberg Group Publishes New Risk-Based Approach Statement

The Wolfsberg Group published a new statement on the risk-based approach (RBA).

 

 

In an updated statement since its first publication on the RBA in 2006, the Group further defines the core elements of an RBA, aligning with the FATF definition.

The statement outlines three elements financial institutions (FIs) should ensure are reflected in financial crime risk management (FCRM) programmes:

➡️ Proportionality: FCRMs should be proportionate to business models as determined by their size, scale, footprint, customers and risk appetite informed by risk assessments;

➡️ Prioritisation: FIs should prioritise resourcing and attention to higher-risk customers and activities; and

➡️ Effectiveness: FCRMs should deliver effective outcomes, facilitating firms’ responsive, forward-looking and dynamic approaches to risk management, instead of ‘one-size-fits-all’ programmes.

✅ FIs should review the latest Wolfsberg statement when designing and assuring their FCRM programmes, ensuring that programmes continue to reflect the principles of proportionality, prioritised processes, and delivering effective outcomes.