Next steps: Explore AML software from ComplyAdvantage
Discover why leading financial institutions are choosing ComplyAdvantage’s AI-powered AML software. Book a demo to see it in action.
Get a demoAs we mark the one-year anniversary of the UK’s mandatory reimbursement requirement for victims of authorised push payment (APP) fraud, we must acknowledge the sheer scale of the challenge. APP fraud has reached epidemic proportions globally, causing immense financial damage and eroding consumer trust.
While the regulation was ostensibly a positive step for consumer protection, it also brought significant change to the financial services landscape. While many traditional banks had already been following a voluntary reimbursement code for some time – and had accounted for these costs – the mandatory rule represented a major new burden. Specifically for payment technology firms (PayTechs), this introduced a completely new cost centre that they had to factor into their operations. One year on, it is clear that this regulatory shift has created a genuine strain on the competitiveness of the PayTech industry.
While mandatory reimbursement helps victims, the challenge remains that it doesn’t address the underlying systemic issues that allow criminals to operate.
The financial services industry must now focus on a full-scale offensive. The key to solving the problem of APP fraud lies in a proactive, whole-of-ecosystem prevention strategy that breaks down the silos between the various entities criminals exploit. We cannot effectively tackle these scams unless we fight them from multiple angles.
This coordinated, comprehensive effort requires four key pillars:
Fraudsters are increasingly leveraging advances in artificial intelligence (AI) to create highly convincing and scalable scams. Financial institutions (FIs) must counter this with superior technology, including leading-edge technologies and advanced prevention systems to tackle fraud at its source. Firms must constantly assess their control frameworks and strive to stop the payment while it is in progress, rather than simply reimbursing after the fact.
Fraud often exploits weaknesses across different sectors, making accountability a shared concern. We need a mandatory shared responsibility framework that enforces accountability from Telcos and Tech Platforms. These entities are frequently the point of origin for scams, whether through number spoofing, data breaches, or hosting fraudulent investment advertisements.
Criminal networks are transnational, making a siloed defense ineffective. To disrupt the criminal business model, we need:
The human element remains the primary target for fraudsters. Enhanced and effective consumer education is vital to making consumers more resilient to social engineering and common scam tactics, thereby reducing the attack surface for fraudsters.
By committing to this holistic approach, one that is proactive and shared across all key platforms, we can finally hope to achieve a fundamental disruption of the criminal business model and end the epidemic of APP fraud.
Discover why leading financial institutions are choosing ComplyAdvantage’s AI-powered AML software. Book a demo to see it in action.
Get a demoOriginally published 07 October 2025, updated 07 October 2025
Disclaimer: This is for general information only. The information presented does not constitute legal advice. ComplyAdvantage accepts no responsibility for any information contained herein and disclaims and excludes any liability in respect of the contents or for action taken based on this information.
Copyright © 2025 IVXS UK Limited (trading as ComplyAdvantage).