Wolfsberg Group Responds to HM Treasury AML/CTF Consultation

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.