SKN | Bank of Ireland UK Fined £3.7 Million for Confirmation of Payee Failures: Implications for Swiss Private Banking Clients

Key Points:

• Bank of Ireland UK was fined £3.7 million by the UK’s Payment Systems Regulator for missing the deadline to implement the Confirmation of Payee system.
• Over £6.9 billion in transactions were initially processed without the protection, exposing clients to higher fraud risk.
• HNWI and cross-border clients should consider operational resilience and compliance execution when evaluating correspondent banks.

Global regulators are increasingly emphasizing operational rigor in banking infrastructures, particularly those involved in high-value, cross-border payments. On February 19, 2026, the UK Payment Systems Regulator imposed a £3.7 million fine on Bank of Ireland UK for implementing the mandated Confirmation of Payee (CoP) protocol 14 months past the regulatory deadline. This enforcement underscores the strategic importance of operational resilience for private banking clients who rely on correspondent banking and international payment systems to preserve capital and maintain efficiency.

Confirmation of Payee: Core Risk Control

The Confirmation of Payee system is designed to ensure that funds are directed to the intended recipient account, mitigating the risk of authorized push payment (APP) fraud and misdirected transfers. Bank of Ireland UK’s delay meant that more than 1.14 million transactions, totaling approximately £6.9 billion, lacked CoP protection.

For Swiss private banking clients, this is more than a compliance issue; it represents an operational risk that could affect liquidity and cross-border fund flows. Even established institutions may lag in implementing critical fraud safeguards, which has direct implications for capital preservation and operational certainty within multi-jurisdictional banking structures.

Operational Resilience and Counterparty Evaluation

Private banking relationships rely heavily on the stability and reliability of correspondent banks. The Bank of Ireland UK fine demonstrates that regulatory non-compliance can expose clients to operational friction and potential financial loss. For high-net-worth families, this highlights the importance of evaluating the operational and compliance track records of counterparties.

Key considerations include compliance execution, ensuring banks implement required safeguards on time and maintain a history of operational discipline; payment rail stress testing, evaluating potential bottlenecks in cross-border transfers and identifying failure points before they impact liquidity; and counterparty risk mapping, understanding where primary and secondary risks exist across correspondent networks to safeguard capital and transactional efficiency.

Strategic Implications for Swiss Private Banking Clients

Swiss private banks in Zurich and Geneva are renowned for risk management and regulatory compliance, yet the performance of correspondent partners can influence the reliability of cross-border operations. Delays in fraud protection protocols can affect liquidity timing, expose clients to operational risk, and influence reputational discretion.

For clients with multi-jurisdictional banking arrangements, the enforcement against Bank of Ireland UK reinforces that operational resilience is critical for capital preservation and legacy planning. Banks that integrate robust anti-fraud and compliance mechanisms into their networks offer a superior foundation for cross-border wealth management, ensuring efficient execution and reducing exposure to systemic operational risks.

Forward-Looking Considerations

The Bank of Ireland UK enforcement serves as a cautionary reminder for HNWI clients that regulatory and operational diligence extends beyond primary Swiss banking relationships. Monitoring correspondent banks, reviewing payment system safeguards, and aligning operational risk management with wealth preservation strategies will remain key priorities in 2026. Integrating these considerations into cross-border banking decisions strengthens portfolio resilience, enhances transactional efficiency, and ensures that high-value funds are safeguarded against both fraud and systemic disruptions.

For a confidential discussion regarding the operational resilience and compliance of your cross-border banking structure, contact our senior advisory team.