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Behind the Regulations: WTR Articles & Commentary
Fresh thinking, expert analysis & practical insight into the regulations
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This section features original articles that explore the evolving landscape of wire transfer regulation, from technical obligations and enforcement trends to policy debates and future reforms. Written with clarity and insight, these pieces are designed to challenge assumptions, unpack complexity, and offer practical perspectives across compliance, risk, and payments.
Whether you're looking for strategic commentary or operational insight, these articles provide thought-provoking content grounded in real-world relevance.
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Identity Matters: How VASPs Verify Customers to Meet UK MLR & Travel Rule Requirements
As the cryptoasset sector continues to evolve, regulation is rapidly catching up with technological innovation. In the UK, Virtual Asset...

Elizabeth Travis
12 minutes ago6 min read
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FATF Recommendation 16 & the Politics of Compliance
FATF Recommendation 16, commonly referred to as the Travel Rule, sits at the heart of the international framework designed to combat illicit financial flows. It requires that countries ensure financial institutions include accurate and required information about both the originator and the beneficiary in all wire transfers. This information must accompany the transfer throughout its lifecycle. The rule applies equally to traditional wire transfers and to transfers involving v

Elizabeth Travis
Nov 176 min read
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Payment Processors: The Unseen Gatekeepers of Global Transfers
The integrity of the UK’s financial system increasingly depends on entities that few consumers have ever heard of. Payment processors, which form the technical backbone of electronic transactions, now sit at the intersection of financial innovation and regulatory accountability. Their systems enable billions of transfers every day, yet their role in anti-money laundering (AML) compliance has remained largely unexamined outside specialist circles. That is changing. The Financi

Elizabeth Travis
Nov 106 min read
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Who Really Complies? Rethinking FATF Recommendation 16
The architecture of the global anti-money laundering (AML) regime is often understood through the lens of geopolitical power. Countries like the United States, UK, and Germany are widely perceived as leaders in financial regulation, while developing nations are frequently cast as compliance laggards. Yet a close examination of technical compliance with the Financial Action Task Force’s (FATF) Recommendation 16 (R.16) reveals a surprising inversion of this narrative. The Evol

Elizabeth Travis
Nov 35 min read
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Wire Transfer Regulations & Islamic Banking: Navigating the Crossroads of Compliance & Faith
Wire Transfer Regulations (WTRs) are pivotal in the global effort to combat money laundering, terrorist financing, and the illicit...

Elizabeth Travis
Oct 276 min read
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Why Banks Think Wire Transfer Regulation is Less Important & Why They’re Wrong
In the labyrinthine world of financial regulation, institutions face an ever-expanding array of compliance requirements. From market...

Elizabeth Travis
Oct 205 min read
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The UK Wire Transfer Regulation: The Problem Isn’t Just the FCA, It’s the Law Itself
The Wire Transfer Regulation (WTR) was designed to safeguard transparency in cross-border payments by requiring complete payer and payee information to accompany every transfer. Yet recent FCA data released under Freedom of Information shows that this requirement is being routinely breached. Between 2020 and mid-2025, firms reported 265 cases of payment service providers repeatedly failing to supply the necessary details such as names, addresses or account numbers. The striki

Elizabeth Travis
Oct 165 min read
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The Travel Rule & the Illusion of Transparency: Reimagining R.16 for a Fragmented Financial Future
In the architecture of global anti-money laundering (AML) and counter-terrorist financing (CTF) regimes, Recommendation 16 of the...

Elizabeth Travis
Oct 137 min read
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Peaks & Troughs: What WTR Reporting Fluctuations Reveal About AML Oversight
The Mystery of the Curve In theory, regulatory reporting should be a steady drumbeat. If Payment Service Providers (PSPs) repeatedly fail...

Elizabeth Travis
Oct 85 min read
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Payment Rails & the Wire Transfer Regulations: Infrastructure Meets Obligation
The financial system’s capacity to transfer value swiftly and securely across borders hinges on what are known as payment rails; the...

Elizabeth Travis
Oct 66 min read
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FCA Data Exposes Gaps in Enforcement of AML: Hundreds of Breaches, No Visible Consequences
The UK’s financial regulator has been quietly collecting hundreds of warnings about repeat anti-money laundering (AML) breaches. What it...

Elizabeth Travis
Oct 26 min read
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Language Barriers in Wire Transfer Regulation: Why the World Still Can't Agree
In the fragmented world of financial crime compliance, language has become a surprising obstacle. Regulators and international bodies...

Elizabeth Travis
Sep 296 min read
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