The Wolfsberg Group response to EBA’s ML/TF risk factors

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The Wolfsberg Group has published its response to the EBA’s Public Consultation on revised Guidelines on money laundering and terrorist financing (ML/TF) risk factors (EBA/CP/2023/11).

The response covers the Group’s views on proposed changes to:

  • Definitions;
  • Guideline 1: Risk assessments: key principles for all firms;
  • Guideline 2: Identifying ML/TF risk factors;
  • Guideline 4: CDD measures to be applied by all firms;
  • Guideline 6: Training;
  • Guideline 8: Sectoral guideline for correspondent relationships;
  • Guideline 10: Sectoral guideline for electronic money issuers; and
  • Guideline 21: Sectoral guideline for crypto asset services providers (CASPs).

Firms can view the Wolfsberg response to the consultation in advance of potential forthcoming changes to the EBA Guidelines.

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