The intergovernmental agreement is about bulk transfer of data, crazy:
On the principle of proportionality: SWIFT cannot, for technical and governance reasons, search the ‘content’ of the messages, and thus cannot search data based on criteria like names, addresses and/or invoice numbers of individuals. Therefore if SWIFT were to receive a (Article 4, FMDA) request to produce data related to e.g. an individual, SWIFT will not be able to produce that specific data because of technical reasons. SWIFT could provide instead ‘data in bulk’. These messages may eventually contain the specific data (e.g. the name or the address of an individual) that the authority needs for counter terrorism purposes. So, by the very nature of SWIFT it is not possible to refer to so-called limited requests.
The above-mentioned implies that SWIFT has to transfer all, or virtually all, of its data to US Treasury. That violates the basic principles of data protection law, i.e. the principles of necessity and proportionality. This cannot be subsequently rectified by mechanisms of oversight and control.