The Wolfsberg Group's 2012 "Principles (or Private Banking" established that.

The Wolfsberg Group's 2012 Principles for Private Banking explicitly established that transparency of client beneficial ownership is necessary, requiring private banks to identify and verify the ultimate beneficial owners of accounts. This principle directly addresses the opacity that makes private banking inherently high-risk for money laundering and financial crime.

While the Principles address due diligence, the specific 2012 establishment centered on beneficial ownership transparency as the primary principle, not framing due diligence specifically in terms of predicate offenses.

The Wolfsberg Principles endorse risk-based approaches as the appropriate method for managing AML risk in private banking, rather than characterizing them as insufficient.

The Wolfsberg Principles focus on establishing AML standards and best practices for private banking, not on coordinating global control environment strategies between banks.