The Wolfsberg Group has published a guidance paper on requests for information (RFIs) as used in anti-money laundering and counter financing of terrorism (AML/CFT) transaction monitoring processes.
The guidance is focused primarily on inquiries initiated as a result of transaction monitoring, and is not intended to address inquiries issued in relation to transactions blocked or rejected as a result of sanctions screening or payment transparency events.
Purpose and scope
An important goal of the guidance is to improve awareness of the value that RFIs provide in a correspondent banking relationship, according to the association of global banks that aims to develop frameworks and guidance for the management of financial crime risks – particularly with respect to policies for know your customer (KYC) and AML/CFT.
It aims to present best practice guidance for both issuing and respondent institutions and to improve the overall effectiveness of the RFI process.
While it deals with correspondent banking, the guidance applies to other payments-based relationships.
Questions and challenges
The guidance aims to add to financial institutions’ understanding of how RFIs should be handled, what types of questions are being asked, the purpose of the question, the role of RFIs in mitigating financial crime risks, and the benefits of effective RFIs and responses.
It explains how there are many elements of the inquiry process that impact the effectiveness of RFIs, such as a lack of inquiry response, insufficient or incomplete responses, privacy concerns restricting information-sharing, delayed responses to RFIs, or misunderstanding of the purpose of the RFI or the RFI process.
An appendix includes a list of commonly asked RFI questions and expected responses from the respondent financial institutions.
The Wolfsberg Group’s RFI Best Practice Guidance can be found here.
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