September 7 • 2023

UKs Authorised Fraud Scams Reimbursement – further updates 

Cybercrime is low risk, low investment, and high return. Not surprisingly, illegal financial gain is one of the biggest reasons for cyber-attacks. The result is a predicted USD 10 Trillion of damages by 2025. Our vision is to change that.

The Financial Services and Markets Act 2023 now has its Royal Assent and is therefore law in the UK. Part of this places requirements on the PSR to mandate reimbursement on Payments forms for APP in certain situations. 

On the back of last year’s consultation, there is now have the proposals as I covered here. There is now a further consultation on the following two elements for Faster Payments

This consultation close on 12th September, with the expectation that the rules will all be agreed before the year end and come in to force around end Q1/start of Q2 2024. 

What are the details of the consultation? 


Proposed three options: 

The factors influencing the setting of the excess level that have been identified are: 

Questions cover these areas: 

Setting the maximum level of excess 

Proposal is for £415k cap, in line with current FOS limit, covers 98.98% by value.

Questions cover these areas: 

The factors influencing the setting of the maximum level that have been identified are: 

Also, there is a proposal for the CHAPs limit (set by the BOE) to be set at the same level, with similar questions in the consultation. 

On balance it must be said that the maximum limit seems fair. In terms of the excess of 5-10% percentage with a cap in the £100-£500ish range seems a potential outcome. 

Overall, this would mean that the majority of victims get a refund of most of their losses, even for small or large amounts, whilst requiring customer caution, however, there might be a lot of small cases requiring lots of automation. 

This would firmly set the UK as the best place to be a victim of scams at least a s consumer. Banks & payment firms now need to take steps to limit fraudulent transactions in the first place as well as reducing mules and onward transmission of funds to reduce their liability here, through greater data sharing throughout the customer lifecycle. This now sets up a next stage of further liability push to big tech platforms. 


At  CYBERA  we’re on a mission to stop money laundering and help protect customers from scams and other financial cybercrime. We close gaps that allow cyber criminals to thrive by sharing crime data in real-time with financial institutions, fintech, and crypto exchanges, and coordinating a global response to support customers who have become victims of financial cybercrime.   

CYBERA WATCHLIST™ helps support firms to reduce fraud and money laundering and meet regulatory requirements as part of a holistic fraud and financial crime strategy.   

Financial Institutions (FIs) can check against the CYBERA WATCHLIST™ for confirmed mule accounts when processing payments. For outbound & inbound payments, where there is a match on either IBAN (Account Number & Sort code) or on Name the transaction can be flagged as high risk.   

At account opening and ongoing CDD, email, phone and name can be used to match to CYBERCRIME WATCHLIST™ to reduce opening new mule accounts.   

CYBERA VSR™ further supports by providing users with alerts of any of their accounts reported as mules directly in their dashboard.   

Unlike other data sources, CYBERA is a global solution, so is well placed to support the increasing levels of cross-border real-time payments.