Wolfsberg Group Responds to EBA ML/TF Risk Factors

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.