Heightened regulatory scrutiny of cross-border payments has intensified expectations on financial institutions to evidence full compliance with Regulation (EU) 2015/847 on information accompanying transfers of funds. As a cornerstone of the EU’s anti-money laundering and counter-terrorist financing framework, the regulation is designed to ensure the traceability of payment flows and prevent their misuse for financial crime.

A large Nordic banking group engaged OpusDatum to deliver an independent review of its wire transfer controls, providing credible evidence of compliance to its national Financial Supervisory Authority (FSA as part of an ongoing supervisory dialogue.

Our Client

Our client is a leading Nordic banking group operating across multiple European jurisdictions, with a high-volume cross-border payments portfolio spanning domestic, SEPA, and SWIFT channels. The bank operates in multiple Payment Service Provider (PSP) roles, including payer, intermediary, and payee PSP, across a complex and decentralised payments infrastructure.

To support regulatory engagement and demonstrate transparency, the bank sought an independent, third-party assessment of its compliance with Regulation (EU) 2015/847 across all relevant payment flows.

The Challenge

The client’s cross-border payments architecture reflected the reality of a large, multi-jurisdictional banking group: a combination of legacy payment systems, country-specific onboarding platforms, and centralised customer data repositories. This complexity created inherent risks around data consistency, completeness, and traceability—key compliance requirements under the wire transfer regulation.

Variations in customer data capture across jurisdictions led to inconsistencies in how payer and payee information was populated in payment messages. In some cases, data formatting differences, character limitations in legacy SWIFT MT messages, or the use of alternative names and addresses increased the risk of truncated or incomplete information being transmitted.

The bank also operated under multiple supervisory regimes, each with differing expectations around the interpretation and enforcement of Regulation (EU) 2015/847. This required a consistent and defensible approach to assurance across payment types, geographies, and PSP roles. Known industry-wide challenges, such as incomplete data in certain domestic payment schemes, further complicated the distinction between sectoral issues and institution-specific control weaknesses.

While the bank had already invested in strengthening its financial crime controls, it required independent validation of its compliance posture that could withstand regulatory scrutiny, clearly evidence findings, and support prioritised remediation.

Our Approach

OpusDatum conducted an independent, data-led review assessing compliance with Regulation (EU) 2015/847 across the client’s roles as payer PSP, intermediary PSP, and payee PSP, covering both cross-border and domestic payment flows.

Our review focused specifically on the presence, completeness, and consistency of mandatory payer and payee information within payment messages processed during a defined review period. A structured testing methodology was applied to compare transaction-level data against regulatory requirements and internal customer records.

Testing was conducted across four core areas: outgoing payments where the bank acted as payer PSP; transactions processed as intermediary PSP to assess data retention and transmission; inbound payments in the role of payee PSP; and domestic payments subject to simplified data requirements.

To ensure consistency, scalability, and evidential robustness, we deployed WireCheck, OpusDatum’s proprietary assurance tool designed specifically for wire transfer regulation compliance. WireCheck automates the identification of missing, incomplete, or non-standard data in payment messages and applies rule-based validation aligned to Regulation (EU) 2015/847. This enabled high-volume testing, structured comparison across systems, and clear documentation of findings.

The integration of WireCheck into the review methodology ensured a repeatable and defensible testing approach, supporting both regulatory engagement and internal remediation planning.

Key Benefits & Measurable Outcomes

The engagement enabled the bank to demonstrate regulatory transparency and accountability through a credible, independent report provided to its national FSA. This proactive approach strengthened supervisory engagement and evidenced a clear commitment to wire transfer regulation compliance.

The review identified specific and actionable remediation opportunities across SEPA, SWIFT, and domestic payment channels, allowing the bank to address data quality issues, message formatting weaknesses, and control gaps in a prioritised and risk-based manner.

Beyond immediate compliance improvements, the findings supported longer-term enhancements to customer data governance by highlighting systemic inconsistencies across onboarding platforms and centralised data repositories.

As a result, the bank is now better positioned to manage wire transfer regulation risks, respond confidently to regulatory enquiries, and strengthen its broader AML control framework with greater clarity and assurance.

Are You Prepared to Evidence Wire Transfer Compliance?

If your institution needs to demonstrate compliance with Regulation (EU) 2015/847 or respond to supervisory scrutiny, OpusDatum can help. Our expert-led, data-driven assurance reviews deliver defensible evidence, actionable insight, and regulatory confidence.

Contact us today to learn how our WireCheck-powered reviews can identify data gaps, strengthen regulatory readiness, and support effective financial crime compliance.