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.