News & Analysis as of

Fraud Payment Systems United Kingdom

Fraud is the making of false representations or engaging in deceptive behavior in order to unlawfully secure financial or personal gain. 
Hogan Lovells

The Payments Newsletter including Digital Assets & Blockchain, July 2025

Hogan Lovells on

Key developments of interest over the last month include: the UK government's communications in connection with the Chancellor's annual Mansion House speech, and the launch of its Financial Services Growth and Competitiveness...more

A&O Shearman

UK APPG publishes report assessing the APP fraud mandatory reimbursement requirement

A&O Shearman on

The UK All-Party Parliamentary Group (APPG) on Fair Banking has published its latest report, "No Half Measures – A Blueprint to Beat APP Fraud", alongside a press release. The report assesses the UK's response to authorised...more

A&O Shearman

PSR consolidated policy statement on APP scams reimbursement requirement

A&O Shearman on

The UK Payments Systems Regulator (PSR) has published a consolidated policy statement (PS25/5) concerning the authorised push payment (APP) fraud reimbursement requirement within the Faster Payments system, which came into...more

A&O Shearman

PSR update on impact of APP fraud reimbursement scheme

A&O Shearman on

The UK Payment Systems Regulator (PSR) has published an update on what it has seen since the implementation of its authorised push payment (APP) fraud reimbursement scheme in October 2024. The data covers UK payments made via...more

Hogan Lovells

UK: A new litigation risk for PSPs? Quincecare claim brought by derivative action is successful

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Ever since the Supreme Court held, in Philipp v Barclays Bank plc1(Philipp), that claims based on the Quincecare duty against the payment services provider (PSP) which paid the funds away were not open to victims of...more

Hogan Lovells

UK: “Duty of retrieval” rejected: why banks do not owe a duty to recover funds lost through APP fraud

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Banking fraud of all types is an ever increasing problem in today’s society, and takes a multitude of forms. On a basic level, frauds can be divided into two types. Unauthorised fraud, where the victim does not provide...more

A&O Shearman

Financial Crime: The FCA’s Strategy for 2025 – 2030

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In its strategy for the next five years, financial crime remains a priority for the UK Financial Conduct Authority (FCA). While the FCA acknowledges the significant efforts firms invest in their anti-financial crime systems,...more

A&O Shearman

PSR publishes policy statement on 2024 APP scams data

A&O Shearman on

The UK Payment Systems Regulator (PSR) has published a policy statement outlining its approach to publishing authorised push payment (APP) scams data for 2024. In 2025, the PSR will take a different approach to publishing...more

A&O Shearman

UK Financial Conduct Authority Dear CEO letter on priorities for payments portfolio firms

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The Financial Conduct Authority has published a Dear CEO letter to firms in the payments portfolio sector (including payment institutions, e-money institutions and registered account information service providers). Although...more

A&O Shearman

The U.K.'s Authorised Push Payment (APP) Fraud Reimbursement Scheme

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The UK’s Authorised Push Payment (APP) Fraud Reimbursement Scheme came into force on October 7, 2024. It requires in-scope payment service providers (PSPs) sending payments through either the Faster Payment System (FPS) or...more

A&O Shearman

The U.K.'s Authorised Push Payment APP Fraud Reimbursement Scheme

A&O Shearman on

The UK’s Authorised Push Payment (APP) Fraud Reimbursement Scheme came into force on October 7, 2024. It requires in-scope payment service providers (PSPs) sending payments through either the Faster Payment System (FPS) or...more

Hogan Lovells

UK APP fraud: What in-scope PSPs need to know about the new mandatory reimbursement regime

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Over the past few years, the Payment Systems Regulator (PSR) and Bank of England (BoE) have published a huge number of consultations, guidance documents and specific directions outlining the requirements under the new regime...more

A&O Shearman

UK Financial Ombudsman Service Updates Guidance on Handling Complaints Concerning APP Fraud, Scams and Fraud

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The Financial Ombudsman Service has published updated versions of its guidance for businesses on: (i) handling complaints concerning Authorized Push Payment fraud and other scams involving authorized payments or withdrawals;...more

Hogan Lovells

UK APP fraud mandatory reimbursement regime: Next steps for PSPs and overview of key publications

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With the new mandatory reimbursement requirements for Faster Payments and CHAPS now in force, we provide a quick reference guide to the key publications to date. As in-scope payment service providers (PSPs) move into the...more

Hogan Lovells

APP fraud: FCA consults on Approach Document changes to support proposed payments delay legislation

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The FCA is consulting on amendments to its Payment Services and Electronic Money Approach Document to provide guidance for payment service providers (PSPs) on how to apply the proposed outbound payments delay legislation...more

BCLP

Mandatory Reimbursement for App Fraud: What Payment Service Providers Need to Consider Ahead of Implementation

BCLP on

The controversial new requirement for all in-scope Payment Service Providers (“PSPs”) to reimburse victims of Authorised Push Payment (“APP”) fraud are due to be introduced from 7 October 2024. This is a significant change...more

Hogan Lovells

APP fraud: UK PSR draft guidance on distinguishing between APP scam claims and civil disputes

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The Payment Systems Regulator (PSR) is consulting on draft guidance to support payment service providers (PSPs) in their assessment of whether an APP scam claim raised by a consumer is not reimbursable under the new...more

A&O Shearman

Draft UK Legislation to Address Push Payment Fraud

A&O Shearman on

HM Treasury has published a policy note and a draft statutory instrument—The Payment Services (Amendment) Regulations 2024—on a risk-based approach to payments to mitigate against authorized push payment fraud. HM Treasury...more

Skadden, Arps, Slate, Meagher & Flom LLP

New Rules To Tackle Authorised Push Payment Fraud

Authorised push payment (APP) fraud in the UK is the largest type of payment fraud, both in number of scams and value of losses. It involves a fraudster convincing someone to send a payment to a bank account that the...more

BCLP

Play Safe - How scam-proof are you in the new world of mandatory reimbursement for APP fraud?

BCLP on

Imagine this – a customer submits a payment instruction directing that all their life savings are transferred to a third-party account for the purposes of an investment. What do you do? While the scenario may appear...more

Goodwin

The FCA’s 2023/24 Priorities for UK Payments: Firms and Investors, Take Note

Goodwin on

On March 16, 2003, the UK Financial Conduct Authority (FCA) published its letter Portfolio Letter: FCA priorities for payments firms to the CEOs of UK Payment Institutions (PIs), Electronic Money Institutions (EMIs), and...more

Hogan Lovells

Payments regulatory news, December 2020 # 2

Hogan Lovells on

PIs and EMIs: HM Treasury consults on a new special administration regime - HM Treasury is consulting on proposed insolvency changes for payment institutions (PIs) and electronic money institutions (EMIs), including a...more

BCLP

Payment Fraud: PSP’s Obligations

BCLP on

In accordance with recent UK Finance statistics, in 2019 banks and card companies prevented £1.8 billion in unauthorised payment fraud and between 2018 and 2019 APP fraud losses increased by almost 30% to £456 million. In...more

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