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Behind the Regulations: WTR Articles & Commentary
Fresh thinking, expert analysis & practical insight into the regulations
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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Kenya: Balancing Innovation & WTR Oversight in East Africa’s Fintech Hub
Kenya’s financial landscape is routinely held up as proof that innovation can widen access while fuelling real-economy growth. M-Pesa turned basic mobile phones into wallets long before “fintech” entered the lexicon, and the ecosystem has matured into cross-border rails that connect consumers and small firms to regional and global markets. The question is no longer whether Kenya can innovate. It is whether the regulatory perimeter can keep pace with a system that now moves va
Elizabeth Travis
7 days ago5 min read
Integrity, Inclusion & FATF’s Grey List
The October 2025 plenary of the Financial Action Task Force (FATF) marked a turning point in the politics and perception of international compliance. South Africa and Nigeria, two of Africa’s largest and most systemically significant economies, were formally removed from the Grey List, having demonstrated what the FATF described as “substantial progress” in strengthening anti-money laundering and counter-terrorist financing (AML/CFT) systems. For both countries, this decisio
Elizabeth Travis
Dec 15, 20256 min read
FATF Recommendation 16: The UK Benchmark, Tested by Reality
The Financial Action Task Force’s Recommendation 16 (R.16), commonly known as the ‘Travel Rule’, mandates that originator and beneficiary information must accompany all wire transfers. This obligation lies at the heart of the global anti-money laundering (AML) and counter-terrorist financing (CTF) system, enabling authorities to trace illicit financial flows, identify criminal networks, and safeguard the integrity of cross-border transactions. In today’s financial landscape,
Elizabeth Travis
Dec 8, 20255 min read
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 17, 20256 min read
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 3, 20255 min read
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 16, 20255 min read
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 13, 20257 min read
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 8, 20255 min read
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 2, 20256 min read
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 22, 202511 min read
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 8, 20254 min read
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 1, 20254 min read
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