Screening & checksIntermediate

APP fraud and the mandatory reimbursement regime

Most fraud people picture involves a stolen card or a hacked account. Authorised push payment (APP) fraud is different and, in many ways, harder: the victim themselves is tricked into authorising a payment to a fraudster. Because the customer pressed "send", it long fell outside traditional fraud protections. That changed: since 7 October 2024, UK payment firms must reimburse most APP-fraud victims. It is one of the most consequential consumer-protection and financial-crime reforms in years.

What APP fraud is

In an APP scam, the fraudster manipulates the victim into sending money from their own account — by impersonation, a fake invoice, a romance scam, a bogus investment, or a "safe account" trick. The payment is genuine and authorised by the customer, which is exactly why it was hard to challenge.

APP
APP fraudUnauthorised fraud
Who sends the moneyThe victim, deceivedThe fraudster, without consent
Example"Your account is at risk — move funds to this safe account"Stolen card used to buy goods
Historic protectionWeak — the customer "authorised" itStronger — clearly not the customer
NowMandatory reimbursement (since Oct 2024)Long-standing chargeback/refund rights

The mandatory reimbursement regime

Brought in by the Payment Systems Regulator, the regime applies to APP scams over Faster Payments made on or after 7 October 2024.

£85,000
the maximum mandatory reimbursement per claim
5
working days within which in-scope PSPs must reimburse
50/50
the cost split between sending and receiving payment firms
How
  1. Victim is scammed
    They authorise a payment to a fraudster and realise they were deceived.
  2. Claim to their PSP
    The victim reports it to their payment service provider.
  3. Assessment
    The PSP assesses the claim against the scheme rules (with limited exceptions).
  4. Reimbursement
    In-scope claims are reimbursed, generally within five working days, up to the cap.
  5. Cost sharing
    The sending and receiving PSPs share the loss 50/50.

This is where APP fraud meets anti-money laundering, and why it belongs in a compliance curriculum.

Why
  • Fraudster needs somewhere to receive stolen fundsoften a "money mule" account
  • Receiving PSP should detect the mule accountvia KYC, monitoring, screening
  • Better AML controlsfewer mule accounts

The 50/50 cost split deliberately gives the receiving firm skin in the game: the account that received the fraudulent funds is frequently a money mule account that stronger customer due diligence and transaction monitoring should have flagged. Fraud prevention and AML are two sides of the same coin.

PracticeIs this APP fraud?1 / 4

Decide whether each case is authorised push payment (APP) fraud covered by the reimbursement regime.

'Safe account' bank impersonation

A caller posing as the victim's bank persuades them to move savings to a 'safe account' that the fraudster controls.

Where Probitas fits

APP-fraud defence depends heavily on stopping mule accounts and knowing who is really behind a counterparty. A Probitas check screens individuals and businesses against sanctions, PEP and adverse media sources and surfaces the public record, anchored to its origin — supporting the due diligence that keeps mule accounts and fraudulent counterparties out. The payments controls and reimbursement decisions remain the firm's own.

APP

What is authorised push payment (APP) fraud?

A scam in which the victim is deceived into authorising a payment from their own account to a fraudster — for example through impersonation, fake invoices, romance or investment scams, or "safe account" tricks. The payment is genuine, which is what made it hard to challenge.

Do banks have to refund APP fraud victims?

Since 7 October 2024, in-scope UK payment service providers must reimburse most victims of APP scams made over Faster Payments, up to a maximum of £85,000 per claim, generally within five working days — subject to limited exceptions.

Who pays for the reimbursement?

The cost is split 50/50 between the sending payment firm and the receiving payment firm. This gives the receiving firm — whose account took the fraudulent funds — a direct incentive to prevent mule accounts.

Are all APP fraud claims reimbursed?

No. The scheme has exceptions, such as where the customer acted with gross negligence or where there is first-party (complicit) fraud. A consumer standard of caution applies. It is a strong protection but not unconditional.

How does APP fraud relate to anti-money laundering?

The accounts that receive APP-fraud proceeds are frequently money mule accounts. Stronger AML controls — customer due diligence, screening and transaction monitoring — reduce mule accounts and therefore the success of APP fraud, which is why the two disciplines are closely linked.

Sources

This guide is written from primary sources. Each is linked below; claims in the text link to the specific reference they rely on.

  1. Payment Systems Regulator — APP fraud reimbursement protections
  2. Payment Systems Regulator — APP scams
  3. UK Finance — Authorised Push Payment Fraud Reimbursement
  4. FCA — Financial Crime Guide