Publication of the CBDDQ, FCCQ, Guidance, Glossary and FAQs

On 10 February 2023, the Wolfsberg Group issued a press release, announcing the publication of Version 1.4 of the Correspondent Banking Due Diligence Questionnaire (CBDDQ) and Version 1.2 of the Financial Crime Compliance Questionnaire (FCCQ), along with updated supporting Guidance, Glossary and FAQs documents.
The Basel Committee on Banking Supervision (BCBS), the Committee on Payments and Market Infrastructures (CPMI), the Financial Action Task Force (FATF) and the Financial Stability Board (FSB) have recognised the CBDDQ „as being one of the industry initiatives that will help to address the decline in the number of correspondent banking relationships by facilitating due diligence processes“.
„The CBDDQ aims to set an enhanced and reasonable standard for cross-border and/or other higher risk correspondent banking due diligence, reducing to a minimum any additional data requirements, as per the Wolfsberg definition and current FATF Guidance. It is also the Group’s expectation that the Group members will use the CBDDQ, in a phased approach, with all of their respondents.
In the long term, it is the Group’s view that the adoption of a standardised, reasonable CBDDQ should engender a less arduous, and thereby inherently less costly, due diligence process for correspondent banks, which, as it beds down, should also allow for a standard which all Financial Institutions, and their supervisors, can work towards achieving. This should, in the end, support the objectives of the G20 and other supranational organisations towards a well supervised and more harmonised regulatory standard in the correspondent banking space, with longer term positive effects on de-risking, access to finance, the development of trade and financial inclusion“.
—
The present CBDDQ updates „include a new section on Fraud and additional questions related to Whistleblower Policy, Virtual Bank License, the approval of Sanctions Policy, and other changes designed to improve the logic, usability and flow of the questionnaire. The Declaration Statement has been updated to include a revised period for update of the Questionnaire. Commensurate changes were made to the FCCQ (which is a shorter version of the CBDDQ and contains a basic set of questions to address Industry demand) to ensure consistency with CBDDQ v1.4.
The previously issued Completion Guidance and Capacity Building Guidance have been combined into a single guidance document, which highlights the potential risk addressed by questions and considerations the Respondent should make while responding to the question. Guidance notes are also provided for those questions where further explanation or definition would serve to aid readers’ understanding.
The FAQ and Glossary documents have also been updated to address changes in the Questionnaires. Of note in the FAQs, the recommended timeframe for update of the Questionnaires has been adjusted to 12-18 months. This change addresses concerns of perceived expiration date of the questionnaire on a specific date which can cause delays when this date does not align with CDD review period.“
All documents are attached to this RISP-event, but can also be directly downloaded on the dedicated CBDDQ-section of the Wolfsberg Group website.