Increased regulatory scrutiny over the transparency of cross-border payments has made it imperative for financial institutions to demonstrate full compliance with Regulation (EU) 2015/847 on information accompanying transfers of funds. This regulation forms a critical component of the European Union’s anti-money laundering and counter-terrorist financing framework, ensuring the traceability of financial flows. A large Nordic banking group proactively commissioned an independent third-party assurance review to assess its compliance with wire transfer obligations. The purpose of the engagement was to provide a credible assurance report to its national Financial Supervisory Authority (FSA) as part of a wider supervisory engagement.

Our Client

Our client is a leading Nordic banking group with operations across multiple European jurisdictions and a high-volume cross-border payments portfolio. With a complex payments infrastructure supporting domestic, SEPA, and SWIFT transactions, the client acts in varying roles as payer, payee, and intermediary Payment Service Provider (PSP). The bank sought independent assurance to assess its compliance posture and demonstrate transparency to its primary regulator.

The Challenge

As a large cross-border banking group operating across multiple jurisdictions, our client's payment processing architecture involved a mix of legacy systems, country-specific onboarding platforms, and centralised customer data repositories. This fragmentation increased the risk of inconsistencies between customer records and the information transmitted in payment messages, a critical compliance risk under the wire transfer regulation.

A key challenge lay in ensuring that payer and payee details, such as name, address, and account number, were accurately populated and retained throughout the payment lifecycle. Differences in how customer data was captured and stored across markets led to variations in data formatting, occasional truncation, and in some cases, the use of alternative names or addresses in outgoing payments. These issues were compounded by the character limitations imposed by older payment message formats, particularly SWIFT MT messages, which are still widely used in cross-border transactions.

Our client also operated in multiple regulatory environments, each with its own supervisory expectations and interpretations of compliance obligations. This created pressure to deliver a consistent level of assurance across payment channels, regardless of whether the transaction originated domestically, within the EEA, or beyond. Additionally, known industry-wide issues, such as missing account numbers in domestic payments in certain markets, required careful handling to distinguish between systemic sectoral challenges and institution-specific weaknesses.

Crucially, whilst our client had already invested in strengthening its financial crime controls, it required independent validation of its compliance status that could stand up to regulatory scrutiny. The challenge was not only to identify gaps and inconsistencies but to do so in a way that provided clear evidence, prioritised remediation, and demonstrated transparency and cooperation with its supervisory authority.

Our Approach

We conducted an independent, data-driven assurance review to assess the organisation’s compliance with Regulation (EU) 2015/847 across multiple PSP roles: acting as payer PSP, intermediary PSP, and payee PSP for both cross-border and domestic transfers. Our review focused exclusively on the presence, completeness, and consistency of mandatory payer and payee information in payment messages processed during a defined period.

A structured testing methodology was applied to compare and validate each transaction, highlighting potential gaps in alignment with regulatory requirements. Our methodology was structured around four distinct areas:

• Outgoing payments where the organisation acted as payer PSP, verifying that required details such as the payer’s name, account number, and address were accurately reflected in the payment instructions.

  
  

• Transactions where the organisation acted as intermediary PSP, evaluating whether payer and payee information was retained and transmitted without alteration.

  
  

• Inbound payments in the role of payee PSP, focusing on the completeness of payer information received.

  
  

• Domestic payment compliance, ensuring that simplified data requirements under the regulation were consistently met.

To ensure consistency, accuracy, and efficiency across the testing process, we used WireCheck, our proprietary assurance tool, purpose-built to support compliance with wire transfer regulations. WireCheck automates the detection of missing, incomplete, or non-standard data in payment messages and supports structured comparison between internal customer records and transaction-level data. Its validation engine applies rule-based logic aligned to Regulation (EU) 2015/847, enabling rapid identification of potential non-compliance across large payment volumes.

By integrating WireCheck into our review methodology, we delivered a scalable and repeatable testing process that enhanced the quality of the assurance findings. The tool not only enabled a consistent approach across all payment types, but also provided clear evidence to support regulatory engagement and internal remediation planning.

By leveraging transaction-level data, a standardised testing methodology and the use of a purpose-built RegTech product, we delivered a meaningful assurance statement that supported the client’s supervisory dialogue and compliance planning.

Key Benefits & Measurable Outcomes

The review enabled the bank to demonstrate regulatory transparency and accountability by providing a credible third-party assessment to its national FSA. This proactive approach strengthened the bank’s supervisory relationship and showed clear commitment to meeting its obligations under Regulation (EU) 2015/847.

The review identified specific areas for remediation across SEPA, SWIFT, and domestic payment channels, allowing the bank to address gaps in data quality and message formatting. These findings formed the basis of a practical and risk-based compliance roadmap, helping to prioritise enhancements efficiently.

In addition to addressing immediate compliance issues, the engagement supported longer-term improvements to customer data governance. By highlighting inconsistencies across systems, the review informed broader efforts to align onboarding processes and centralised records with regulatory expectations.

Overall, the bank is now better equipped to manage wire transfer regulation compliance risks, respond to regulatory enquiries, and strengthen its AML controls with greater clarity and confidence.

Are you prepared to evidence compliance with EU wire transfer regulations?

Contact us today if your institution requires an independent wire transfer compliance review or needs to demonstrate readiness to regulatory authorities. We provide expert-led, data-driven assurance that enhances transparency, mitigates financial crime risk, and supports regulatory confidence.

Learn how our WireCheck-powered assurance reviews can help you identify data gaps, strengthen regulatory readiness, and demonstrate proactive financial crime compliance.