In October 2000 11 leading international private banks, including Credit Suisse and United Bank of Switzerland, agreed to adopt the Wolfsberg Anti-Money Laundering Principles as global guidance for sound business conduct in international private banking. The Wolfsberg Principles set out general guidelines for preventing the use of a bank's worldwide operations for criminal purposes. Banks will endeavour to accept only those clients whose sources of wealth and funds can be reasonably established to be legitimate. The primary responsibility for this lies with the private bank that sponsors the client for acceptance. Beneficial ownership must be established for all accounts, whether held by individuals or legal entities, including trusts and unincorporated associations. According to the Wolfsberg Principles, the bank will collect and record information on the following matters:
  • purpose and reasons for opening the account;

  • anticipated account activities;

  • source of wealth;

  • estimated net worth;

  • source of funds; and

  • references or other sources to corroborate information on the client's reputation.

Additional diligence will be required with regard to high-risk countries identified as having inadequate anti-money laundering standards, offshore jurisdictions, high-risk activities known to be susceptible to money laundering and public officials. With respect to this last category, individuals who hold or have held positions of public trust (eg, government officials, senior executives of government or corporations, politicians and important political party officials) and their families and close associates require heightened scrutiny.

The Wolfsberg Principles outline the practice to be used when identifying unusual or suspicious activities, and establish guidelines on supervision, control, responsibilities, reporting and training for employees. Participating banks must establish an adequately staffed and independent department responsible for the prevention of money laundering.

Adoption of the Wolfsberg Principles will have little practical impact on banks located in Switzerland, as national law already imposes stringent obligations on Swiss banks in relation to the identification of clients. However, the fact that major international private banks have decided to join forces to combat money laundering is a further step towards protecting the global banking system from involvement in money laundering schemes. The Swiss Banking Commission is particularly sensitive to any initiative in this respect.

The Wolfsberg Principles and a list of participating banks can be found at

For further information on this topic please contact Guy-Philippe Rubeli at Pestalozzi Lachenal Patry by telephone (+41 22 80 94 500) or by fax (+41 22 80 94 501) or by e-mail ([email protected]).

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