On 30th October, 2000, a new initiative to combat money laundering was unveiled. What differentiates this initiative from many of the existing initiatives is that it has been put forward by the private sector. Eleven banks signed a set of principles known as the Wolfsberg Anti‐Money Laundering Principles (the ‘Wolfsberg Principles’). The Wolfsberg Principles are a non‐binding set of best practice guidelines governing the establishment and maintenance of relationships between private bankers and clients. Over the past decade much has been written about money laundering, the problems it creates for the economic, political and social institutions of countries, and the need to combat the phenomenon. Most initiatives to date have been public sector led by governments and their regulatory and law enforcement agencies, or by government representatives acting through international forms such as the Financial Action Task Force (FATF) and the Basel Committee of Bank Supervisors. Consequently, most initiatives have focused on enacting new criminal laws, implementing reporting requirements, and developing codes of best practice. The fact that the private sector has taken the initiative to establish the Wolfsberg Principles is therefore worthy of closer analysis. As Dr Peter Eigen, the Chairman of Transparency International, observed on the release of the Wolfsberg Principles, ‘This is a unique event — few would expect the leading anti‐corruption organisation and the leading banks to be standing on the same platform’. The following article examines the Wolfsberg Principles in order to identify the various strengths and weaknesses of each. First, however, it is worth noting in brief the background to the Wolfsberg Principles and the regulatory paradigm within which they are to operate.
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