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Insights and Expertise




        A view from the UK:                                     Once sent, these funds are typically gone for good, with
                                                                little recourse.
        APP, where are we                                       According to UK Finance, UK losses in 2023 totaled an

                                                                alarming £459.7 million, with online platforms responsible
        now?                                                    for 76 percent of cases. While most digital scams involve
                                                                frequent,
                                                                                                         phone-based
                                                                                          transactions,
                                                                           smaller-value
                                                                variants, though less common, tend to extract significantly
                                                                larger sums from targets.
                                                                To address what had long been a regulatory and
                                                                reputational sore spot, the Payment Systems Regulator
                                                                (PSR) mandated that as of October 2023, both sending and
                                                                receiving banks share liability for reimbursing APP fraud
                                                                victims. Payouts must be processed within five working
                                                                days, up to a cap of £85,000.

                                                                The reform was designed to level the playing field and
                                                                offer consumer protections in line with the sophistication
                                                                of today’s fraud threats. But these changes have not landed
                                                                quietly.

                                                                Reimbursement gains and industry fallout
                                                                The first and most visible outcome of the rule change has
                                                                been a marked increase in consumer reimbursements.
                                                                More victims are now getting their money back, a clear
        By Roger Alexander                                      win for individuals previously left without remedy. But
        Chargebacks911                                          this victory for consumers has brought with it a wave of
                                                                resistance from across the financial sector.
              t’s been just over nine months since the UK intro-
              duced sweeping reforms targeting authorized push   Payment firms, especially smaller fintechs and PSPs
              payment (APP) fraud, a milestone that offers a    handling real-time payments, are warning that the cost
        I chance to reflect on the reforms' impact so far.      burden imposed by the new liability framework is putting
                                                                untenable strain on their businesses.
        While it's still too early for a full assessment, the ripple
        effects across the payments sphere are already undeniable:   A number of providers have already made the difficult
        an  industry  shaped  by  consumer  compensation  rules,   decision to wind down operations or exit the UK market
        rising operational pressure on providers, and changing   entirely. One notable casualty, the eco-focused fintech firm
        fraud tactics that are testing the limits of prevention for   Tred, pointed to the APP fraud rules as a direct factor in
        businesses.                                             their closure earlier this year, stating that the new model
                                                                made their business unviable.
        APP fraud remains one of the fastest-growing financial
        crimes. Distinct from other forms of fraud, APP scams   Fraudsters adapt, so do banks
        involve victims being conned into willingly authorizing   Predictably, fraudsters have adjusted swiftly to the new
        payments to criminals, usually under misleading         regulatory terrain. As liability shifted, the sophistication
        fabrications.                                             of scams kept pace. Voice cloning, deepfake scams and
                                                                  artificial intelligence-driven impersonation attacks are
                                                                  gaining ground, making it harder than ever for users to
          One notable casualty, the eco-focused                   discern legitimate communication from manipulation.

          fintech firm Tred, pointed to the APP                   This uptick in tech-enhanced fraud presents a major
               fraud rules as a direct factor in                  challenge for fraud prevention teams and further
                their closure earlier this year,                  complicates the job of customer authentication.
              stating that the new model made                     The new environment has also accelerated a broader
                                                                  conversation about risk allocation. For years, consumers
                    their business unviable.                      bore the bulk of APP fraud consequences, often with
                                                                  limited support. Now, some financial firms argue the
                                                                  pendulum has swung too far in the other direction.
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