Wire transfer regulations (WTR) are a critical component of the global framework to combat money laundering and terrorist financing. Under Regulation (EU) 2015/847, financial institutions are subject to strict legal obligations to ensure that all qualifying transfers of funds include complete and accurate payer and payee information. Failure to meet these requirements exposes firms to regulatory sanction, operational disruption, and reputational damage.

OpusDatum was engaged to support a major UK retail bank in reviewing and strengthening its adherence to wire transfer regulation obligations, with a particular focus on ensuring that non-compliant payments could be identified, paused, or prevented from being released.

Our Client

Our client is a major UK retail and commercial bank operating a ring-fenced structure and serving millions of customers across a broad range of domestic and international payment services. With significant volumes of inbound, outbound, and intermediary wire transfers, the bank faced material compliance and operational risk if data completeness obligations were not consistently met across payment channels.

The Challenge

The bank required assurance that all payments originating from, passing through, or terminating at the institution complied with Regulation (EU) 2015/847. Beyond confirming technical compliance, the bank needed to understand whether effective preventative or detective controls existed to stop the release of funds where mandatory payment information was missing or incomplete.

Where such controls were absent or ineffective, the bank needed a clear understanding of root causes and practical remediation options that could be implemented without disrupting core payment operations. This required a detailed assessment across all three potential PSP roles—payer, intermediary, and payee—within the constraints of a ring-fenced operating model.

Our Approach

OpusDatum worked closely with stakeholders across Payment Operations, the First Line of Defence, and Financial Crime Compliance to define the scope of payments subject to the regulation. This collaborative approach ensured a shared understanding of regulatory obligations and how they translated into operational practice.

Where a formal compliance standard did not exist—particularly within the ring-fenced entity—we developed and documented a consistent interpretation of regulatory requirements. This provided a clear benchmark against which existing processes and controls could be assessed.

Our review was structured around the bank’s three PSP roles:

Payer PSP

We assessed whether mandatory originator and beneficiary information was consistently populated from customer due diligence systems into payment messages. Where data gaps or inconsistencies were identified, we traced root causes such as product design limitations or channel-specific constraints. Existing monitoring controls were evaluated, and where gaps remained, we recommended targeted process enhancements and training to reduce recurrence.

Intermediary PSP

We mapped end-to-end intermediary payment flows to assess whether the bank could halt or escalate transactions where required information was missing. Control weaknesses were analysed to identify systemic causes, leading to tailored recommendations covering system changes, revised procedures, and strengthened escalation routes. We also reviewed reporting mechanisms and staff awareness to ensure regulatory expectations were met.

Payee PSP

We examined inbound payments to determine whether controls existed to detect and remediate non-compliant transactions before funds were released to customer accounts. Where weaknesses were identified, we proposed practical control enhancements and operational changes to ensure compliance prior to crediting funds.

Across all roles, we supported the development of key risk and performance indicators to provide ongoing visibility of compliance performance and embed accountability within operational teams.

Key Benefits & Measurable Outcomes

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

Consistent Regulatory Alignment

A clear, documented interpretation of Regulation (EU) 2015/847 eliminated ambiguity across teams and ensured consistent application of data completeness standards for all payment roles.

Stronger Preventative and Detective Controls

Enhanced controls enabled the bank to pause or stop non-compliant payments prior to release. Where real-time prevention was not feasible, alternative escalation and mitigation measures were introduced to reduce operational and regulatory risk.

Root Cause Remediation

Systemic drivers of non-compliance—including CDD data integration gaps, channel limitations, and inconsistent processes—were identified and addressed, strengthening end-to-end control resilience.

Improved Operational Ownership

Clearer procedures, targeted training, and defined accountability empowered first-line teams, reducing reliance on second-line intervention and embedding compliance into day-to-day operations.

Enhanced Management Oversight

Tailored KPIs and KRIs provided senior management with improved visibility of risk exposure and control performance, supporting proactive oversight and continuous improvement.

Are You Prepared to Evidence Wire Transfer Compliance?

Wire transfer compliance demands more than technical solutions—it requires clear interpretation, effective controls, and demonstrable operational discipline.

If your institution needs to review or strengthen its adherence to Regulation (EU) 2015/847, OpusDatum can help. Our expert-led, operationally grounded reviews identify gaps, strengthen controls, and support confident engagement with regulators.

Contact us today to learn how our WireCheck-powered assurance reviews can enhance regulatory readiness and reduce financial crime risk.