The Key Bodies — Egmont, Wolfsberg, Basel, IMF/World Bank *(OUTLINE + BULLET BODY)*

In the last lecture, FATF gave us the rulebook — the 40 Recommendations. But FATF doesn't run an account, it doesn't share a suspicious-transaction tip across borders, and it doesn't write the questionnaire your correspondent bank makes you fill out. Other bodies do that work. On the CAMS® exam, you will get a question that names four organizations and asks "which one does X?" — and the wrong answers will all be real organizations doing real, but different, jobs. So this lecture is a sorting exercise. By the end you'll be able to hear "FIU-to-FIU information sharing" and instantly think Egmont, hear "correspondent banking due diligence questionnaire" and think Wolfsberg — every time.

- FATF sets the standards; these four bodies operationalize, supplement, or assess against them. None of them replaces FATF. - Two are private-sector/operational membership groups (Egmont, Wolfsberg), one is a banking-supervisory standard-setter (Basel), and the IMF/World Bank are intergovernmental financial institutions that assess and assist. - Exam framing: know the one-line "what does this body produce or do?" for each.

- Founded 1995 at the Egmont-Arenberg Palace in Brussels; an informal network, now formalized, of national **Financial Intelligence Units (FIUs)**. - An FIU is the national central agency that receives suspicious transaction reports (SARs/STRs), analyzes them, and disseminates financial intelligence to law enforcement. In the US, the FIU is **FinCEN**. - Egmont's core purpose: secure **FIU-to-FIU exchange of financial intelligence** across borders — money laundering is transnational, so FIUs need a trusted channel to share. - The secure channel is the **Egmont Secure Web (ESW)**. - Egmont supports FATF Recommendation 29 (countries must have an FIU) and Recommendation 40 (international cooperation). Membership requires a functioning, FATF-consistent FIU. - Exam cue words: "FIU," "financial intelligence sharing between countries," "1995," "Egmont Secure Web." Egmont does NOT supervise banks and does NOT write CDD rules.

- A private association of **global banks** (founded 2000, named for the Château Wolfsberg in Switzerland). It is an industry body, not a regulator — it publishes voluntary **guidance and standards**, not law. - Best known for guidance on **correspondent banking**, **private banking**, and AML principles, plus monitoring/screening and beneficial-ownership statements. - Flagship tool: the **Wolfsberg Correspondent Banking Due Diligence Questionnaire (CBDDQ)** — a standardized questionnaire a respondent bank completes so a correspondent bank can assess its AML controls. It standardizes due diligence so banks aren't each inventing their own forms. - Why it matters: correspondent banking is high-risk because a bank provides services to another bank's customers it never directly onboarded (nested relationships). Wolfsberg's DDQ is the industry-standard answer. - Exam cue words: "private banks," "industry guidance," "correspondent banking questionnaire / DDQ / CBDDQ." Wolfsberg sets no binding law and runs no list.

- Hosted at the **Bank for International Settlements (BIS)** in Basel, Switzerland; the global standard-setter for **prudential banking supervision**. - AML-relevant output: the 2001 paper **"Customer Due Diligence for Banks"** and the consolidated guidance **"Sound management of risks related to money laundering and financing of terrorism."** - Emphasizes **KYC/CDD as a component of sound risk management and safety-and-soundness**, not just an AML compliance task — poor KYC is a prudential (reputational, operational, legal) risk to the bank itself. - Stresses ongoing customer due diligence, group-wide risk management, and the responsibilities of bank boards and senior management. - Exam cue words: "banking supervision," "customer due diligence for banks," "Bank for International Settlements / BIS," "sound risk management." Basel is about supervisory standards, not sharing intelligence and not running sanctions lists.

- The **International Monetary Fund (IMF)** and the **World Bank** are intergovernmental financial institutions. In AML/CFT they conduct **assessments** of countries' frameworks and provide **technical assistance and capacity-building**, especially for developing economies. - They assess AML/CFT regimes using the FATF methodology (historically conducting some FATF-style mutual evaluations) and incorporate AML/CFT into broader **Financial Sector Assessment Program (FSAP)** reviews. - They do NOT set the AML standards (FATF does) and do NOT enforce them — they help countries measure against and build toward the standards. - Exam cue words: "technical assistance," "capacity building," "assessing countries' frameworks," "FSAP." Don't confuse the IMF/World Bank's *assessing* role with FATF's *standard-setting* role.

- **FATF** → sets the standards (40 Recommendations), runs grey/black lists, does mutual evaluations. - **Egmont** → connects national **FIUs** for cross-border financial-intelligence sharing (Egmont Secure Web). - **Wolfsberg** → private banks' **voluntary guidance**; the correspondent-banking **DDQ/CBDDQ**. - **Basel** → banking-supervision standards; **CDD for banks** as sound risk management (at the BIS). - **IMF/World Bank** → **assess** national frameworks and provide **technical assistance**. - The trap: all four are real and all touch AML — match the verb in the question (share, question, supervise, assess) to the body.

So, the sorting rule one more time: FATF writes the standards, Egmont lets the FIUs talk to each other, Wolfsberg gives banks the correspondent-banking questionnaire, Basel tells banks that KYC is part of sound risk management, and the IMF and World Bank assess countries and help them build their systems. Match the verb to the body and these questions become free points. Next up, we cross the Atlantic and land in the United States — the most heavily tested national framework on the exam. In the next lecture we tackle the Bank Secrecy Act: Currency Transaction Reports over ten thousand dollars, Suspicious Activity Reports, recordkeeping, MSB registration, and the role of FinCEN.