Wire transfer regulations (WTR), governed under Regulation (EU) 2015/847 and retained in UK law post-Brexit, impose absolute legal obligations on payment service providers to transmit accurate and complete payer and payee information with every qualifying transaction. Although often treated as an extension of AML controls, WTR represents a distinct regulatory and operational risk arising from the structural realities of payment processing rather than customer behaviour.

OpusDatum supported a Tier 1 UK bank in identifying, assessing, and embedding WTR-specific risks into its enterprise-wide risk assessment (EWRA), strengthening governance, regulatory defensibility, and board-level oversight.

Our Client

Our client is a leading UK-based Tier 1 bank with a global footprint across consumer, commercial, and institutional banking. The bank processes significant payment volumes across SWIFT, SEPA, CHAPS, and FPS, and is also involved in virtual asset transfers through regulated VASPs.

Operating across all three PSP roles—payer, intermediary, and payee—the bank maintained a mature financial crime framework. However, WTR risks had not been explicitly articulated within its enterprise risk taxonomy, limiting visibility of this exposure at senior governance levels.

The Challenge

Regulatory scrutiny around wire transfer compliance was increasing, with supervisors expecting firms to demonstrate a clear understanding of WTR-specific risks and how they are managed. While technical controls existed, WTR obligations had not been formally identified or assessed within the bank’s EWRA.

This represented a material gap. Unlike AML risks, WTR obligations apply irrespective of transaction risk or suspicion and are breached through operational failures such as data truncation, formatting errors, or inappropriate use of derogations. The challenge was to identify where WTR risks arose within payment workflows, assess their likelihood and impact, and produce structured, defensible outputs aligned to the bank’s operational risk framework.

Our Approach

OpusDatum conducted cross-functional workshops to map the bank’s end-to-end wire transfer activity across all PSP roles. Using methodologies aligned to our WireCheck assurance tool and WTR risk assessment methodology, we traced payment journeys to identify structural failure points, including legacy system constraints, inconsistent message formatting, derogation misuse, and weak detection of placeholder or truncated data.

We deliberately distinguished WTR risks from traditional AML risks by focusing on message integrity, system behaviour, and control execution rather than behavioural indicators or customer risk ratings. This distinction ensured that WTR was assessed as an operational and regulatory risk in its own right.

Each PSP role was assessed separately to reflect distinct legal obligations and control expectations. For payer PSP activity, we examined the verification and mapping of mandatory payer data into structured payment messages. For intermediary PSP activity, we assessed whether message integrity was preserved during transformation and relay. For payee PSP activity, we evaluated procedures for detecting deficient incoming messages, escalation practices, and tracking of repeat failures in line with FCA expectations.

Risk scoring followed the bank’s internal methodology but was enhanced through residual risk calibration based on observed control performance. This included assessment of data lineage, control gaps, RFI handling, and post-event monitoring. Outputs were structured for direct inclusion into EWRA documentation and presented to senior risk forums for validation and challenge.

Key Benefits & Measurable Outcomes

The engagement enabled the bank to formally recognise WTR as a standalone regulatory risk class, distinct from general AML exposure. Risk statements and control assessments were grounded in the technical realities of payment processing, improving accuracy and relevance.

The EWRA now incorporates WTR-specific inherent and residual risks aligned to PSP roles, payment channels, systems, and jurisdictions. These risks are supported by evidence-based narratives and embedded within the bank’s operational and compliance risk registers, improving board-level visibility and governance oversight.

Operational accountability was strengthened through clearer ownership of WTR controls. Dashboards and metrics derived from the assessment now track derogation usage, control failures, and RFI volumes, supporting proactive risk management and regulatory engagement.

Importantly, the bank can now evidence a proportionate, risk-based approach to WTR compliance, including documented procedures for identifying repeatedly failing PSPs and managing supervisory interactions. The work also established a foundation for future automation, supporting ISO 20022 migration and real-time message validation.

Is Your Wire Transfer Risk Fully Reflected in Your EWRA?

Wire transfer compliance is no longer a back-office consideration—it is a material operational risk that demands enterprise-level attention.

If your institution needs to identify and embed wire transfer regulation risks across payer, intermediary, and payee PSP roles, OpusDatum can help. Our expert-led, data-driven assessments—powered by WireCheck—deliver actionable insight, strengthen regulatory alignment, and support confident supervisory engagement.

Contact us today to discuss how we can support your wire transfer risk and governance objectives.