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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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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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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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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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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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Too Many Gatekeepers? The Fragmented Role of Regional FATF Bodies in Wire Transfer Regulations
Wire transfer regulations, especially those derived from FATF Recommendation 16 (R.16), are foundational tools in the global fight...
Elizabeth Travis
Sep 2211 min read
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Tick-Box Compliance or Intelligence-Led Regulation? Wire Transfer Regulation in Brazil & the UK
Wire transfers are a core conduit for international commerce and financial flows, but they also pose significant risks for money...
Elizabeth Travis
Sep 84 min read
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The New North American Hierarchy: Why Mexico Is Now the Gold Standard for the Travel Rule
The Financial Action Task Force’s (FATF) consolidated technical compliance table, refreshed on 23 April 2025, has laid bare a striking...
Elizabeth Travis
Sep 14 min read
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From Grey List to Gold Standard? Wire Transfer Regulation in South Africa & the UK
Wire transfer regulations are pivotal in the global effort to combat money laundering and terrorist financing. By ensuring the...
Elizabeth Travis
Aug 254 min read
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US Wire Transfer Regulation Compliance: The Trump–Biden–Trump Arc
Wire transfer regulation compliance is the backbone of the United States AML/CTF framework. Each day trillions of dollars move through...
Elizabeth Travis
Aug 117 min read
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Tracing the Flow: Wire Transfer Regulations in Nigeria
Wire transfers remain a vital conduit for both legitimate global commerce and illicit finance. In jurisdictions with complex financial...
Elizabeth Travis
Aug 45 min read
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