Three steps to dramatically improve the quality of your wire data.

Think back to the last time you reviewed a spreadsheet of wire transfer data from your AML data store. Did it seem to you that you were missing information in the originating bank role or the beneficiary bank role? What percent of the time did it feel like that information was missing?

If the answer is less than 5% of the time, stop reading.

If the answer is greater than 5% of the time, you've got some work to do. You're intelligent and experienced enough to know what kinds of problems missing wire data can cause an AML group; inaccurate profiling, incorrect alerts, incomplete search results, increased staff work load to get the missing data from the raw wire messages.

Fortunately, there are three simple steps to fix that problem.

1. Insist that every wire transfer has an originating bank and a beneficiary bank.
2. Map the originating bank by stepping through the optional and mandatory tags on the wire message.
3. Map the beneficiary bank by stepping through the optional and mandatory tags on the wire message.

First, insist that every wire transfer has an originating bank and a beneficiary bank. All of them. All the time. If either of those roles were truly missing, the money would not move. Practice saying this. Say it out loud now, just to hear it. Write it on a whiteboard. Make it a data quality standard.

Second, Map the Originating Bank.

In a SWIFT message, (the concept applies to FedWire and CHIPs messages, but we'll just talk about SWIFT for the moment) some parts of the message are optional, and some are mandatory. More importantly for you, there is a logical hierarchy to the information.

SWIFT tag 52 is the Ordering Institution, aka the originating bank. Tag 52 is an optional tag. I can't tell you the number of times I've had the following conversation when reviewing wire data.

“There's no originating bank on this wire record”

“There was no originating bank on the wire.”

“Really?”

“Sure, here's a copy of the wire message. We're supposed to look for tag 52 for the originating bank and put that information in the AML system. This one doesn't have a tag 52, so, we don't have an originating bank.”

Can you remember a conversation like that?

SWIFT, in its manuals, establishes rules and reasoning for interpreting the contents of a wire message, and to be successful in your wire monitoring, you need to make that reasoning part of the logic used to parse the wire message into effective AML information.

So, instead of this logic;

if tag 52 is present map contents to “originating bank”

else map blanks to “originating bank”

Use this logic:

If tag 52 is present, map contents to “originating bank”

else if tag 51 (Sending Institution) is present, map to “originating bank”

else map tag 2 (sending BIC in message header) to “originating bank”

Tags 52 and 51 are optional, but the sending BIC in the message header is mandatory. Even better, it has to be a valid BIC.

It's just as simple for a FedWire message;

if {5100} is present, map contents to “originating bank”

else map {3100} to “originating bank”

Third: Map the Beneficiary Bank.

Again, instead of stopping if an optional tag is not used; implement a mapping hierarchy that always ends on a mandatory field.

Instead of

if tag 57 (Account With Institution) is present, map the contents to “Beneficiary Bank”

else map blanks to “Beneficiary Bank”

use this simple substitution;

if tag 57 (Account With Institution) is present, map the contents to “Beneficiary Bank”

else map the BIC in tag 1 (receiving BIC) to “Beneficiary Bank”

Again, tag 1 is mandatory, and, bonus!! It's a valid BIC.

For the FedWire fans;

if {4100} is present, map the contents to “Beneficiary Bank”

else map {3400} to “Beneficiary Bank”.

{4100} is optional, but if it's used, it has the data you want. If it's not used, the {3400} tag, which is mandatory, has the data you need.

Three simple steps to vastly improve your AML wire transfer data;

1. Insist on populating the originating and beneficiary bank roles in every wire, every time.
2. Enhance your mapping logic to obtain the originating bank information.
3. Enhance your mapping logic to obtain the beneficiary.