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How to Design & Implement Exception Handling Procedures

Why It Matters

Even the most comprehensive validation and monitoring controls cannot eliminate every issue. Occasionally, wire transfer payments will arrive with missing, incomplete, or questionable information about the payer or payee. Regulations such as EU Regulation 2015/847 and FATF Recommendation 16 require financial institutions to respond to these exceptions using documented, risk-based procedures. It is not enough to detect problems; institutions must be able to demonstrate how exceptions are assessed, resolved, and recorded in a controlled and auditable way.


What Is a WTR Exception?

An exception arises when a payment does not meet the required data standards. This could occur because mandatory payer or payee details are missing, corrupted, or entered in the wrong field. Sometimes the data may appear as placeholder text, contain irrelevant characters, or fail formatting rules due to incompatibilities between message formats like SWIFT MT and ISO 20022. Exceptions can happen in both outgoing and incoming transactions, often flagged by real-time validation systems, transaction monitoring tools, or manual review processes.


Core Principles of Exception Handling

Effective exception handling is built on a foundation of several core principles. First, institutions must maintain clearly documented standard operating procedures that define the full exception lifecycle from detection and classification through to escalation, remediation, and closure. Second, a risk-based approach must guide decision-making. Not all exceptions are equal; handling must take into account factors such as transaction value, jurisdictional risk, parties involved, and the sender's history.


Third, auditability is essential. Every exception must leave a clear, traceable record of what was found, what was done, and who approved the response.


Exception Handling Workflow





Step-by-Step Exception Handling Workflow



Escalation Triggers

Certain types of exceptions require automatic escalation to senior teams or compliance specialists. These include transactions that are high in value, involve politically exposed persons, originate from high-risk jurisdictions, or show multiple discrepancies across fields. Repeat exceptions from the same counterparty also warrant greater scrutiny, as do payments involving Virtual Asset Service Providers (VASPs).


Exception Governance

Effective governance depends on clear accountability. Institutions must designate responsibility to a specific team or function such as Compliance or Operations and establish service-level agreements (SLAs) to ensure timely resolution, often within 24 to 48 hours. Exception data should feed into management information (MI) reports, highlighting trends in volume, response time, and root causes. Regular reviews should be conducted to identify recurring issues, assess whether controls need updating, and support broader quality improvement initiatives.


Summary

A structured, well-governed exception handling process is a core component of WTR compliance. It demonstrates to regulators that your institution can systematically detect, evaluate, and address payment data issues. This not only supports regulatory obligations but also reduces operational risk, improves data quality, and builds trust with counterparties and supervisors alike.

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