As the Sverdrup balance argues, subtropical ocean gyres have a weak equatorward flow and subpolar ocean gyres have a weak poleward flow over most of their area. However, there must be some return flow that goes against the Sverdrup transport in order to preserve mass balance. In this respect, the Sverdrup solution is incomplete, as it has no mechanism in which to predict this return flow. Contributions by both Henry Stommel and Walter Munk resolved this issue by showing that the return flow of gyres is done through an intensified western boundary current. Stommel's solution relies on a frictional bottom boundary layer which is not necessarily physical in a stratified ocean (currents do not always extend to the bottom).
Munk's solution instead relies on friction between the return flow and the sidewall of the basin. This allows for two cases: one with the return flow on the western boundary (western boundary current) and one with the return flow on the eastern boundary (eastern boundary current). A qualitative argument for the presence of western boundary current solutions over eastern boundary current solutions can be found again through the conservation of potential vorticity. Considering again the case of a subtropical northern hemisphere gyre, the return flow must be northward. In order to move northward (an increase in planetary vorticity ), there must be a source of positive relative vorticity to the system. The relative vorticity in the shallow-water system is:
Here  is again the meridional velocity and  is the zonal velocity. In the sense of a northward return flow, the zonal component is neglected and only the meridional velocity is important for relative vorticity. Thus, this solution requires that  in order to increase the relative vorticity and have a valid northward return flow in the northern hemisphere subtropical gyre.
Due to friction at the boundary, the velocity of flow must go to zero at the sidewall before reaching some maximum northward velocity within the boundary layer and decaying to the southward Sverdrup transport solution far away from the boundary. Thus, the condition that  can only be satisfied through a western boundary frictional layer, as the eastern boundary frictional layer forces . One can make similar arguments for subtropical gyres in the southern hemisphere and for subpolar gyres in either hemisphere and see that the result remains the same: the return flow of an ocean gyre is always in the form of a western boundary current.
The western boundary current must transport on the same order of water as the interior Sverdrup transport in a much smaller area. This means western boundary currents are much stronger than interior currents, a phenomenon called "western intensification".