Second Statement on Effective Monitoring for Suspicious Activity

2025-08-27

The Wolfsberg Group publishes its second Statement on Effective Monitoring for Suspicious Activity

A responsible framework for innovation –

As the economic barriers to leveraging automation, artificial intelligence and machine learning continue to relax, financial institutions are increasingly folding these capabilities into their strategy for monitoring for suspicious activity. In July 2024, the Wolfsberg Group published the Statement on Effective Monitoring for Suspicious Activity, where we encouraged financial institutions to move beyond traditional transaction monitoring, introducing a vision for how we should target and develop effective outcomes as a priority across our monitoring programmes.

We publish today our follow-up to that work, focused on establishing a responsible transition framework for innovation in suspicious activity monitoring. Within this new statement we detail our three core pillars for responsible innovation:

(1) transition and validation; (2) balancing model risk with financial crime risk; and (3) explainability to demonstrate transparency in coverage and effectiveness.

The core aspects of the framework presented within this new statement are drawn from the experiences of the member banks as they have advanced their own approach to monitoring for suspicious activity in their core jurisdictions. The transition framework has also benefited from a series of technical workshops, both virtual and in-person, with financial intelligence units, policymakers, and supervisory authorities across the world.

The Wolfsberg Group welcomes the responsible embrace of innovation, we encourage the application of these principles across the industry, and we will continue to work with supervisory authorities across the world to push for innovation-friendly regulatory environments in the fight against financial crime.

To access the full document, click here.