How to Identify & Respond to Missing or Incomplete Data in a Payment

Why It Matters

Under regulatory frameworks such as EU Regulation 2015/847, the UK Money Laundering Regulations, and FATF Recommendation 16, specific payer and payee information must accompany each payment. Payments that lack this information—or contain only partial details—pose a regulatory risk and undermine the traceability of funds. Unlike meaningless data, which may appear valid but lacks substance, missing or incomplete data refers to the actual absence of mandatory information.

What Is Considered Missing or Incomplete Data?

Examples include:

Blank Fields: e.g. missing payer name, no account number
Partially Filled Fields: e.g. “John” instead of “John Smith”, “Flat 5” with no street name
Incorrect Field Mapping: e.g. payer name submitted in an address field
Omitted Identifiers: e.g. required address or national ID missing when no account number is available
Absence of Transaction Reference: when required under specific messaging standards (e.g. ISO 20022)

Incomplete data differs from meaningless data in that it typically involves legitimate omissions rather than filler or fake inputs.

Step-by-Step Detection & Validation

What to Do When You Find It

Option 1: Request Remediation

Reach out to the initiating party (internal or external) to supply the missing or full data before executing the payment.

Option 2: Escalate if Recurring or Risky

If incomplete data is a repeated pattern or involves high-risk counterparties, raise the case to compliance.

Option 3: Reject the Payment

If the missing information is required and cannot be promptly resolved, reject the transaction.

Documentation Requirements

Record what information was missing
Document who was contacted for follow-up and the result
Log unresolved cases for audit and training purposes

Best Practices

Set up real-time pre-validation of key fields
Apply stricter checks above certain thresholds (e.g. EUR 1,000)
Include missing/incomplete data categories in transaction monitoring reports
Train staff to recognise the difference between blank, partial, and incorrect entries

Summary

Incomplete or missing information can be just as damaging as overtly invalid data. Ensuring that payments carry all legally required fields in the right format is a basic but essential step in complying with wire transfer rules. Institutions should monitor, respond, and remediate data gaps with the same diligence used for other regulatory controls.