The response presents the Group’s reasonings based on the following areas:
- Information Sharing, Public-Private Partnerships and National Threat Priorities;
- Risk-Based and Effective Outcome-Based Supervision;
- Dissuasive Sanctions;
- Supporting Cross-Cutting Government Policies; and
- Sanctions.
The response also includes the Group’s views on the ‘Disadvantages of Model 4’, a Single Anti-Money Laundering Supervisor #SAS.
Firms can view the Wolfsberg response to the consultation in advance of potential forthcoming reforms to the UK’s AML-CTF supervisory regime.