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Wolfsberg - Auditing a Financial Crime Risk Management for Effectiveness


Principles for Auditing a Financial Crime Risk Management Programme for Effectiveness under the Wolfsberg Factors

The Wolfsberg Group (the Group) has encouraged Financial Institutions (FIs) and regulators to focus on effective outcomes in Financial Crime Risk Management (FCRM) using the Wolfsberg Factors:

  1. Complying with financial crime laws and regulations.
  2. Establishing a reasonable and risk-based set of controls to mitigate the risks of an FI being used to facilitate illicit activity.
  3. Providing highly useful information to relevant government agencies in defined priority areas.

The Group believes that Internal Audit (IA) can assist their FIs in the fight against financial crime by measuring FCRM outcomes using the Wolfsberg Factors and has developed these Principles as a joint exercise between member banks’ second and third lines of defence to provide FIs with a framework for such an assessment. IA, an independent function within an FI, constitutes the third line of defence and should conduct independent audits in an objective, thorough, and impartial manner in line with professional standards (e.g. Institute of Internal Auditors). IA should adopt a risk-based approach (RBA) that is informed by applicable laws and regulations and the risks identified in the FI’s risk assessment.

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