2024 update to the Wolfsberg Group on Countering Terrorist Financing
11/03/2024
In 2002, the Wolfsberg Group published a Statement on the Suppression of the Financing of Terrorism.
The document has now been revised and updated to reflect changes in Counter-Terrorist Financing (CTF) measures and the evolving nature of public-private cooperation.
In 2002, the Group published its first Statement on the Suppression of the Financing of Terrorism. Since then, both terrorism and global Counter-Terrorist Financing (CTF) measures have evolved to include:
- Wider adoption of risk-based due diligence standards and practices.
- Greater awareness of terrorist financing behaviours, risks, and typologies.
- Streamlined reporting requirements enabling speedier escalation of cases of suspected terrorist financing.
- Better technology to make detection scenarios more sophisticated; and
- Improved collaboration and coordination through Public-Private Partnerships (PPPs) in many jurisdictions.
In many cases, this has led to more effective provision of information to law enforcement. However, terrorist finance also poses new challenges and considerations, including behaviours, risks and typologies that continue to evolve rapidly, and control implementation may have unintended consequences and reduced legitimate access to the financial system when risk-based approaches have not been carefully implemented.
For these reasons, the 2002 publication has been replaced by this document, which describes the role of financial institutions (FIs) in CTF and the key controls which seek to mitigate and manage the risk of an FI being abused for the financing of terrorism, as part of a risk-based financial crime compliance programme
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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.