Wolfsberg Trade Finance Principles

The Wolfsberg Group Trade Finance Principles paper and appendices were last updated in 2011. Since then regulatory expectations and a more stringent application of existing regulations have made it necessary to review the paper, identify where expectations have changed and, therefore, where the basic principles or their application need to be readdressed.

Since the last revision, the Wolfsberg Group has had an increasingly close dialogue with the ICC to see how the principles could be better disseminated to the ICC membership with a view to raising and standardising the practice level of Financial Crime Compliance (FCC) within the Trade Finance industry.

To date, the only other publicly available guidance, which was specific to the United States, was the January 2008 BAFT IFSA “Guidelines for Bank Secrecy Act/Anti-Money Laundering for Trade Services”1 and a subsequent March 2015 BAFT global update entitled “Guidance for Identifying Potentially Suspicious Activity in Letters of Credit and Documentary Collections.”

In discussion with many practitioners at ICC Banking Commission meetings and other industry events, it became clear that many banks saw the Wolfsberg Principles paper as being for “large global banks” and not for “our smaller, local banks.” There was also the view that if the ICC issued a guidance paper or official publication, then many more banks would see it as important to follow that guidance.

This led to the formation of the joint ICC-Wolfsberg Group Trade Finance Principles Drafting Group in April 2014, with a remit to redraft and update the Wolfsberg Trade Finance Principles paper in the style of ICC guidance, with members drawn from Wolfsberg Group banks, ICC members globally, as well as BAFT so as to broaden the global perspective as part of the drafting group.