Global Momentum for Scam Reimbursement

Why scam reimbursement is rising the global agenda

Reimbursement frameworks are gaining traction as consumer pressure and scam losses climb. Inconsistent refund outcomes, coined by some as the “bank lottery” have undermined public trust in financial services. The UK’s Payment Systems Regulator (PSR) responded with a bold 50:50 liability model for APP (Authorized Push Payment) scams, applicable under Faster Payments and CHAPS. The aim is clear: improve outcomes for victims, rebuild trust and hold financial institutions more accountable.

With the UK’s reimbursement rules now in force for a year (since 7 October 2024), UK Finance reports £450.7m in APP losses in 2024 within £1.17bn total fraud, and 3.13m confirmed cases (+14% YoY). While scam losses remain high, only 3% of claims were deemed “gross negligence” in the first nine months, suggesting early caution by banks and a tightening regulatory lens on definitions like “sufficient intervention.”

Leading the charge

The UK’s approach has been positioned as a blueprint for reform, and its influence is already shaping discussions globally. New Zealand is exploring a reimbursement cap of up to NZD $500,000 as part of ongoing policy consultations, while Singapore has moved ahead with its Shared Responsibility Framework, formally assigning accountability between banks and telcos.

UK banks continue to face key operational questions: what constitutes effective intervention? Is a digital warning enough, or must there be human interaction? These ambiguities are delaying broader adoption elsewhere and highlight the need for clarity and consistent standards.

Across the globe, responses are varying:

• New Zealand: High reimbursement ceiling, but unclear implementation principles.
• Singapore: Conditional reimbursement tied to shared duties of care between banks and telcos.
• Australia: Scam Code is under review; discussions around shared liability are gaining traction.
• Europe: A fragmented environment, with regulators pushing for a PSD3-style directive to mandate best practices across the EU.
• United States: Regulatory response is still nascent, with scam-related policy at an early stage.

While few countries are replicating the UK model outright, its core principles (of shared accountability and consumer protection) are emerging globally. For multinational banks, this creates both operational complexity and a strategic opportunity to drive consistent best practices across markets.

Cross-border complexities and the global bank challenge

Institutions operating globally must now navigate a patchwork of rules. Two customers with identical scam experiences could face entirely different outcomes depending on jurisdiction. This inconsistency not only risks reputational damage but also erodes consumer trust.
For global banks, this reinforces the need for coordinated, policy-agnostic fraud strategies and the right technology infrastructure to support them. Solutions that embed configurable workflows, intelligent orchestration and region-specific compliance rules can help mitigate exposure and operational strain.

Technology’s role

Combatting scams and managing reimbursement fairly requires the ability to detect risk at every stage of the customer lifecycle. Key enablers include:

• Identity verification: Confirms legitimacy during onboarding, preventing fake or stolen identities
• Device intelligence: Detects risky signal changes that may indicate a scam in progress and tracks malicious devices.
• Behavioral intelligence: Flags unusual user behavior linked to scam or mule activity.
• Consortium and third-party intelligence: Strengthens risk signals across the wider ecosystem.
• Machine learning: Correlates signals to reveal emerging risk patterns and prevent mule cash-outs at scale.

At LexisNexis® Risk Solutions, we believe in delivering “seamlessness through certainty.” By enabling banks to collect, connect and act on real-time intelligence signals, before, during and after a transaction, we help financial institutions make confident decisions that protect consumers and meet regulatory expectations.

Expanding risk horizons

As reimbursement frameworks mature, so too does the scope of regulatory interest. We expect growing focus on:

• International payments: Currently excluded from UK PSR, but under scrutiny.
• AI-enabled synthetic identities and mule accounts: Fraudsters increasingly use AI to create realistic personas and automate mule recruitment at scale.
• First-party fraud: Increasing in volume and complexity, often blurring lines of liability.
• Platform and telco accountability: Broader stakeholder responsibility is likely to rise, particularly for scams originating on social media or via telecom channels.

What comes next?

Will we eventually see an internationally aligned reimbursement standard? While global harmonization may be aspirational, cross-border collaboration and shared intelligence networks can help bridge gaps in the meantime. Collaborative ecosystems that unite financial institutions, technology providers, platforms and regulators are increasingly essential. Scam reimbursement is not simply a compliance obligation - it’s a trust imperative. Financial institutions must lead with integrity, backed by technology that empowers intelligent decisioning and global best practice.

At LexisNexis® Risk Solutions, we are committed to supporting this transformation. By uniting identity insights, device and behavioural intelligence and dynamic orchestration, we help our customers meet the demands of a changing regulatory environment, while protecting the consumers who depend on them.