By J. Edward (Ned) Conway, Executive Secretary, The Wolfsberg Group

As virtual assets move into the mainstream of traditional finance, tricky questions arise. What does a reasonable, risk-based control framework look like for banks that provide services to virtual asset service providers (VASPs)? And how can compliance teams strengthen private-to-private information sharing to better detect suspicious activity?

These were some of the questions tackled by the Wolfsberg Group at the 9th Global Conference on Criminal Finances and Cryptoassets, organised by the Basel Institute on Governance, Europol and UNODC and held in Vienna on 28–29 October 2025.

The Wolfsberg Group is an association of 12 global banks that develops frameworks and guidance for the management of financial crime risks. Housed at the Basel Institute on Governance, this long-standing initiative brings together senior financial crime compliance leaders through various working groups, including one dedicated to virtual assets.

This flagship event provided a valuable platform for the Group to explain its Stablecoin Guidance, gauge interest in a specific Due Diligence Questionnaire focused on VASPs, and further advance efforts to break down silos in private-to-private information sharing.

This blog summarises some of the key discussions – dialogues that are continuing in dedicated meetings and consultations of the Wolfsberg Group with members, regulators and institutional partners.

Regulatory clarity as a catalyst for TradFi–VASP relationships?

Day 1 of the conference saw Ned Conway, Executive Secretary of the Wolfsberg Group, moderate a high-level panel discussion featuring representatives from Circle, Bullish and Société Générale on the theme “Bridging the TradFi–DeFi Gap.”

The panel discussed the barriers to relationship building between traditional finance (TradFi) institutions such as banks and VASPs such as cryptocurrency exchanges and stablecoin issuers. The speakers noted that a lack of trust and understanding persists, particularly around risks specific to virtual assets.

That is one reason that TradFi is slow to onboard VASPs as clients and provide them with the banking services they need in order to operate. However, stablecoins are helping bridge this gap by bringing parts of the crypto universe under regulatory frameworks.

TradFi institutions underlined that they would benefit from clearer scenarios from regulators on where collaboration and information sharing would be permissible between regulated entities and VASPs. Recent guidance issued by regulators on stablecoins and virtual assets in Asia, in particular, could help improve confidence both ways in the TradFi-VASP relationship.

Aligning risk appetite, due diligence and monitoring for suspicious activity

On Day 2, a dedicated Wolfsberg side event brought together VASPs, FinTech firms and traditional banks for in-depth discussions. Representatives from several Wolfsberg member banks – Deutsche Bank, Citi, UBS, Société Générale, and Bank of America – joined the sessions.

The agenda focused on frameworks for information sharing, but the discussions touched upon a range of hot topics including:

• risk appetite and the risk-based approach;
• payment transparency (i.e. the travel rule); and
• approaches to monitoring for suspicious activity.

During the discussions, participants highlighted that one of the main barriers to effective collaboration between traditional financial institutions and VASPs is a lack of mutual trust. Both sectors face difficulties in interacting with each other.

The Wolfsberg Correspondent Banking Due Diligence Questionnaire (CBDDQ) is useful for setting standards, but onboarding challenges could be overcome by framing risk in common language. Many viewed the current onboarding approaches as fragmented, and expressed strong support for the Wolfsberg Group to develop standardised guidance and a due diligence questionnaire for VASPs.

Questions remain about what is “reasonable” and “risk-based” for VASPs, especially for smaller institutions, and whether banks should monitor blockchain transactions themselves. VASPs need to be able to articulate their risk appetite, and how this changes as they continue to develop innovative products and services.

VASP participants viewed the Wolfsberg Group’s Stablecoin Guidance as applicable beyond stablecoin issuers to the wider VASP ecosystem. This is particularly true for the tailored questions on the underlying control environment, and the linking of risk appetite directly to monitoring approaches.

Improving private-private information sharing on suspicious activity

Discussion on information sharing between TradFi and VASPs highlighted that this can rely heavily on personal relationships across entities, limiting scalability.

VASPs showed concern around sharing wallet addresses under private-to-private information sharing frameworks, given geopolitical trends and concerns around the EU’s General Data Protection Regulation (GDPR). However, consensus emerged that better data sharing both increases the quality of suspicious activity reports (SARs) and reduces SAR volumes.

Particularly on this latter point, activities often thought to be suspicious in a silo are better understood when viewed from multiple perspectives, confirming the importance of information exchange.

Continuing to build bridges as the financial system evolves

Bridging the gap between TradFi and DeFi remains a central theme in the Wolfsberg Group’s strategy. The Vienna events offered a unique opportunity to engage key stakeholders across the sector and advance this important dialogue.

The side event was opened by Elizabeth Andersen, Executive Director of the Basel Institute on Governance. The Wolfsberg Group extends its sincere thanks to the Basel Institute for the opportunity to co-host this side event and to participate in the 9th Global Conference on Criminal Finances and Cryptoassets.

Learn more

• Learn more about the Wolfsberg Group and explores its guidance and resources on managing financial crime risk, including its Stablecoin Guidance.
• Learn more about the 9th Global Conference and see selected recordings.
• Find out about the 10th Global Conference on Criminal Finances and Cryptoassets on 15–16 September 2026 in Luxembourg.