Authorised Push Payment (APP) fraud continues to be one of the most damaging and rapidly evolving forms of financial crime in the UK. In these scams, victims are tricked into willingly transferring money to fraudsters under the guise of legitimate transactions. Unlike unauthorised fraud, where criminals gain access to accounts without consent, APP fraud exploits trust, making it harder to detect and prevent. The UK has seen significant developments in relation to APP fraud in recent years, including the APP fraud reimbursement requirement (the Reimbursement Requirement) which came into effect in October 2024, further preventative steps taken by industry to reduce instances of fraud and a number of cases working their way through the courts.
In our latest briefing we discuss: (i) some of the issues facing firms in operating the Reimbursement Requirement; (ii) the practical impact of the Reimbursement Requirement; (iii) proposals regarding a review of the Reimbursement Requirement by the Payment Systems Regulator; and (iv) recent litigation relating to APP fraud and the key takeaways for firms.