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Home News Monitoring for Suspicious Activity [SARs/STRs] in line with the Wolfsberg Factors from 2019
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Monitoring for Suspicious Activity [SARs/STRs] in line with the Wolfsberg Factors from 2019

01/07/2024

The Wolfsberg Group [WG] has published a Statement on Monitoring for Suspicious Activity in line with the Wolfsberg Factors from 2019.

The WG:-

  • Takes a firm stance on the current state of SARs/STRs.
  • Believes that the value derived from these reports' (constantly increasing) volume differs from the effective outcomes in the fight against financial crime.

Despite the long-standing discussions on effectiveness by lawmakers, regulators, supervisors, standard setters, and the private sector, the WG asserts.

  • It has yet to integrate fully into the overall Financial Crime Risk Management [FCRM] framework.
  • This integration, it argues, is crucial and will require acceptance and alignment across public and private sectors.

This WG paper

  • Underscores the Wolfsberg Factors as a practical approach to Monitoring for Suspicious Activity (MSA).
  • Describes how these factors can effectively translate into a more practical approach to MSA, highlighting their significance in the process.

The WG has deliberately chosen to:-

  • Characterise this as MSA to cast a wider net than just Transaction Monitoring because customer behaviour and customer attributes can provide a broader insight into potentially suspicious activity when combined with transaction consideration.
  • Therefore, transaction monitoring is a subset of MSA, which might also include concepts such as ongoing Customer Due Diligence (CDD).

This WG paper encourages all parties to

  • Proactively develop innovative techniques and supporting technologies,
  • Which the WG believes will deliver more effective end-to-end risk detection capabilities.

THE PAPER CAN BE READ HERE:-

https://db.wolfsberg-group.org/assets/e3d83d2f-fad9-46d2-b5a9-3cf4e932f53f/Wolfsberg%20Group%20MSA%20Statement%20for%20publication.pdf?utm_source=linkedin&utm_medium=social&utm_campaign=release

MLRO SAR/STR

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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.  

news disclaimer -

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.