DEMO - Wire Transfer Escalation Policy
Overview
This article outlines when and how to escalate wire transfer requests from Commercial/Relationship Management to Compliance, and the documentation clients must provide before a transfer can be processed.
Documentation requirements by transfer size
Transfer amount | Required documentation |
|---|---|
Under $1M | Standard wire authorization form |
$1M–$2M | Wire authorization form + proof of beneficiary account details |
Over $2M | All of the above + Compliance attestation form |
Standard turnaround once complete documentation is received is 1 business day. Incomplete submissions reset this clock.
When to escalate to Compliance
Escalate a conversation to Compliance (move to the compliance@stubbornbank inbox, or tag and notify) when:
The client is requesting a transfer over $2M and has not yet submitted a Compliance attestation
A transfer of any size involves a beneficiary account the client hasn't used with us before
The client's documentation raises any discrepancy against account records on file
A Relationship Manager has been unable to confirm documentation requirements within the standard reply window
Tagging requirements
Every wire transfer conversation should be tagged appropriately so it's tracked in reporting:
Apply Wire Transfer when the conversation involves documentation, cutoff timing, or transfer mechanics
Apply Escalation when a conversation has been outstanding without resolution and requires prioritized attention or Compliance involvement
Response time expectations
Commercial inbox conversations carry a 1-hour reply time goal
If a wire transfer question is not answered within that window, it will be flagged with an SLA warning or breach tag — treat these as priority even if the client hasn't followed up again
Standard response
Relationship Managers can use the "Wire Transfer – Documentation Requirements" message template to respond quickly and consistently. Do not modify the documentation thresholds in the template without Compliance sign-off.
FAQ
What if a client disputes the documentation requirement? Escalate to Compliance directly rather than making an exception — do not waive documentation requirements at the Relationship Management level.
What if the client has submitted documentation before, for a smaller amount? Documentation requirements are evaluated per transaction, not per client history. A new attestation is required for any transfer crossing the $2M threshold, even for repeat clients.
Who approves exceptions to this policy? Compliance team leads only. Relationship Managers should not approve exceptions independently.