Wolfsberg - Auditing a Financial Crime Risk Management for Effectiveness
27/03/2024
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:
- Complying with financial crime laws and regulations.
- Establishing a reasonable and risk-based set of controls to mitigate the risks of an FI being used to facilitate illicit activity.
- 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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As well as owning and publishing Comsure's copyrighted works, Comsure wishes to use the copyright-protected works of others. To do so, Comsure is applying for exemptions in the UK copyright law. There are certain very specific situations where Comsure is permitted to do so without seeking permission from the owner. These exemptions are in the copyright sections of the Copyright, Designs and Patents Act 1988 (as amended)[www.gov.UK/government/publications/copyright-acts-and-related-laws]. Many situations allow for Comsure to apply for exemptions. These include 1] Non-commercial research and private study, 2] Criticism, review and reporting of current events, 3] the copying of works in any medium as long as the use is to illustrate a point. 4] no posting is for commercial purposes [payment]. (for a full list of exemptions, please read here www.gov.uk/guidance/exceptions-to-copyright]. Concerning the exceptions, Comsure will acknowledge the work of the source author by providing a link to the source material. Comsure claims no ownership of non-Comsure content. The non-Comsure articles posted on the Comsure website are deemed important, relevant, and newsworthy to a Comsure audience (e.g. regulated financial services and professional firms [DNFSBs]). Comsure does not wish to take any credit for the publication, and the publication can be read in full in its original form if you click the articles link that always accompanies the news item. Also, Comsure does not seek any payment for highlighting these important articles. If you want any article removed, Comsure will automatically do so on a reasonable request if you email info@comsuregroup.com.