Wire transfer regulations are a critical component in the fight against money laundering and terrorism financing. Under Regulation (EU) 2015/847, financial institutions are required to ensure that transfers of funds contain complete information on the payer and the payee. This case study outlines how OpusDatum supported a major UK retail bank to review and improve its adherence to these regulatory standards. The primary objectives were to verify compliance with the regulation for all in-scope payments and to ensure that effective controls existed to prevent or pause the release of funds on non-compliant transactions.

Our Client

Our client, a major UK retail and commercial bank, operates a ring-fenced structure and serves millions of customers through a broad range of payment services. With a high volume of domestic and international wire transfers, the bank is exposed to considerable compliance and operational risk if data completeness obligations are not met.

The Challenge

The bank needed assurance that all payments originating from, passing through, or terminating at the institution complied with Regulation 2015/847. Beyond compliance, the project required a thorough evaluation of whether the bank had preventative or detective controls in place to stop the release of funds where payment data was incomplete. If such controls were missing or ineffective, root cause analysis and corrective measures were necessary to bring operations in line with regulatory expectations.

Our Approach

We began by working closely with stakeholders across the Payment Operations Team, the First Line of Defence, and Financial Crime Compliance to define the scope of payments subject to the regulation. This collaborative effort ensured a shared understanding of both the regulatory obligations and the operational environment.

Where no formal compliance standard existed, particularly within the ring-fenced entity, we developed and documented a common interpretation of regulatory requirements. This formed a unified benchmark to assess current processes and controls. Our review covered the bank’s three potential roles in wire transfers.

• As Payer PSP:

We assessed whether originator and beneficiary information was being reliably populated from the Customer Due Diligence (CDD) system. Where data was missing or inconsistent, we identified root causes such as deficiencies in product design or limitations within specific channels. We then designed practical controls to close these gaps and evaluated existing monitoring capabilities for detecting outbound non-compliant payments. Where gaps remained, we recommended process improvements and staff training to reduce recurrence.

• As Intermediary PSP:

We mapped out current processes to determine how the bank handled transfers where it acted as an intermediary. Particular attention was paid to whether funds could be halted if required information was incomplete. Where control weaknesses were found, we investigated systemic root causes and developed tailored interventions. These included system changes, revised procedures, and improved escalation routes. We also assessed reporting mechanisms and identified where procedural or awareness gaps needed to be addressed.

• As Payee PSP:

We examined inbound payments where the bank was the payee institution. This involved evaluating whether existing controls allowed the bank to detect and remediate non-compliant payments before releasing funds to customer accounts. Where weaknesses were identified, we proposed control enhancements and operational changes to ensure compliance prior to the release of funds.

Throughout the engagement, we supported the development of key risk and performance indicators to monitor the bank’s compliance posture. These metrics helped embed ongoing oversight, operational discipline, and transparency at senior management level.

Key Benefits & Measurable Outcomes

The engagement delivered measurable improvements across compliance, operations, and governance.

The bank achieved consistent regulatory alignment across all payment roles by establishing a clear, documented interpretation of Regulation 2015/847. This eliminated ambiguity between teams and ensured that every payment, whether outbound, inbound, or intermediary, met the required data standards.

We strengthened the preventative and detective control environment, enabling the bank to pause or stop non-compliant payments before release. Where controls were not feasible in real time, alternative measures and escalation paths were introduced, improving decision-making and reducing operational risk.

Root causes of non-compliance were systematically identified and addressed. These included gaps in CDD data integration, channel-specific limitations, and inconsistent processes across products. By tackling these issues at the source, the bank enhanced its end-to-end compliance resilience.

Operational teams were empowered through clearer procedures, targeted training, and greater first-line ownership. This improved efficiency, reduced reliance on second-line functions, and embedded compliance more deeply within day-to-day processes.

Finally, we supported the design of tailored KPIs and KRIs to track performance and risk exposure. These metrics provided senior management with greater visibility and control, enabling proactive oversight and continuous improvement.

Conclusion

This engagement demonstrated the value of an end-to-end compliance review underpinned by regulatory expertise and operational pragmatism. OpusDatum’s approach enabled the client to significantly enhance its wire transfer compliance posture, reduce financial crime risk, and establish a sustainable control environment.

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