Wire transfer regulations (WTR), as governed under Regulation (EU) 2015/847 and retained in UK law post-Brexit, impose absolute legal obligations on payment service providers (PSPs) to transmit accurate and complete payer and payee information with every cross-border transaction. While often viewed as an extension of AML controls, WTR presents a distinct and complex regulatory exposure that stems from the structural and operational characteristics of payment processing.

This case study outlines how OpusDatum helped a Tier 1 UK bank to identify, assess, and embed WTR-specific risks into its enterprise-wide risk assessment (EWRA), strengthening its governance posture and regulatory readiness.

Our Client

Our client is a leading UK-based Tier 1 bank with a broad global footprint, operating across consumer, commercial, and institutional banking services. With significant payment volumes traversing SWIFT, SEPA, CHAPS and FPS, and involvement in virtual asset transfers through regulated VASPs, the bank operates in all three PSP roles: payer, payee, and intermediary. While it maintained a mature financial crime framework, it lacked a granular view of WTR risks within its enterprise risk taxonomy.

The Challenge

The bank faced growing regulatory pressure to demonstrate its understanding and management of specific risks arising from wire transfer obligations. Although technical controls were in place, WTR risks had not been explicitly assessed or articulated within the bank’s EWRA. This created a material oversight, especially given the absolute compliance nature of the WTR where obligations apply regardless of suspicion or transaction risk profile. The challenge was to identify where WTR risks emerged, assess their likelihood and impact, and provide structured, defensible outputs aligned to the bank’s broader operational risk framework.

Our Approach

OpusDatum began by conducting cross-functional workshops to map the bank’s wire transfer activity across all PSP roles. Using methodologies aligned with our WireCheck framework and supported by our WTR risk assessment methodology, we traced each stage of the payment process to identify structural failure points. These included legacy system formatting issues, inconsistent derogation logic, and weak controls for detecting truncated or placeholder data.

We distinguished WTR risks from traditional AML risks by focusing on the operational fidelity of payment messaging, rather than behavioural indicators or transactional red flags. This distinction was vital: whereas AML risks are often addressed through customer-level risk ratings, WTR risks emerge from systems, workflows, and data integrity within the payment infrastructure itself.

Each role the bank played (as payer PSP, payee PSP, and intermediary PSP) was assessed separately to reflect its distinct regulatory obligations, control expectations, and operational risk exposures.

For payer PSP activities, we examined whether required payer data was consistently verified and correctly mapped into structured message fields. For intermediary PSP activity, we assessed whether the bank’s systems preserved information integrity when reformatting or relaying messages. As payee PSP, we analysed whether the bank had procedures in place to detect and escalate deficient messages, and whether repeat failures were being tracked and reported, in line with FCA expectations.

Risk measurement followed the bank’s internal scoring methodology but was supplemented with residual risk calibration based on real-world control performance. We considered not just the existence of controls, but their effectiveness in a live environment by evaluating data lineage, control gaps, RFI response handling, and post-event monitoring routines. The outputs were then formatted for seamless inclusion into the bank’s EWRA documentation and presented to senior risk forums for validation.

Key Benefits & Measurable Outcomes

Following the assessment, the bank was able to clearly distinguish WTR as a standalone regulatory risk class, separate from general AML exposure. Risk statements and control evaluations were tailored to the technical realities of payment operations, ensuring relevance and accuracy.

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 integrated into the bank’s operational and compliance risk registers. This has improved board-level visibility and created a structured basis for challenge and oversight.

Operational teams were empowered with clearer accountability, and the bank’s control owners now use dashboards and metrics derived from our work to track derogation use, control failures, and RFI volumes. These metrics are shared with governance forums and used to identify emerging risks, trigger remediation, and support regulatory engagement.

Importantly, the bank can now evidence a proportionate, risk-based approach to WTR compliance in line with regulatory expectations. This includes documented procedures for identifying repeatedly failing PSPs and managing interactions with counterparties and regulators. The enhancements also laid the groundwork for automation, supporting future investment in real-time message validation and ISO 20022 migration readiness.

Conclusion

Wire transfer compliance is no longer just a back-office obligation. It is a core operational risk that demands enterprise-level attention. By partnering with OpusDatum, this Tier 1 UK bank has moved beyond tick-box compliance and embedded WTR risks into its strategic risk assessment framework. The result is stronger governance, better regulatory resilience, and a more mature financial crime risk posture.

Is Your Wire Transfer Risk Fully Captured in Your Enterprise-Wide Risk Assessment?

Contact us today if your institution needs to identify and assess wire transfer risks across payer, payee, and intermediary PSP roles. Our expert-led, data-driven reviews - powered by WireCheck -deliver actionable insights that strengthen regulatory alignment, improve control effectiveness, and support confident engagement with supervisory authorities.

Learn how our tailored WTR risk assessments can help you embed compliance into your enterprise risk framework and demonstrate proactive financial crime risk management.