Business
Empowering banks to protect consumers: The impact of the APP Fraud mandate
Source: Finance Derivative
Thara Brooks, Market Specialist, Fraud, Financial Crime & Compliance at FIS
On the 7th October last year, the APP (Authorised Push Payment) fraud reimbursement mandate came into effect in the UK. The mandate aims to protect consumers, but it has already come under immense scrutiny, receiving both support and criticism from all market sectors. But what does it mean for banks and their customers?
Fraud has become a growing concern for the UK banking system and its consumers. According to the ICAEW, the total value of UK fraud stood at £2.3bn in 2023, a 104% increase since 2022, with estimates that the evolution of AI will lead to even bigger challenges. As the IMF points out, greater digitalisation brings greater vulnerabilities, at a time when half of UK consumers are already “obsessed” with checking their banking apps and balances.
These concerns have contributed to the implementation of the PSR’s (Payment Systems Regulator) APP fraud mandate, which was implemented to reimburse the victims of APP fraud. APP fraud occurs when somebody is tricked into authorising a payment from their own bank account. Unlike more traditional fraud, such as payments made from a stolen bank card, APP fraud previously fell outside the scope of conventional fraud protection, as the transaction is technically “authorised” by the victim.
The £85,000 Debate: A controversial adjustment
The regulatory framework for the APP fraud mandate was initially introduced in May 2022. The maximum level of mandatory reimbursement was originally set at £415,000 per claim. The PSR significantly reduced the maximum reimbursement value to £85,000 when the mandate came into effect, however, causing widespread controversy.
According to the PSR, the updated cap will see over 99% of claims (by volume) being covered, with an October review highlighting just 18 instances of people being scammed for more than £415,000, and 411 instances of more than £85,000, from a total of over 250,000 cases throughout 2023. “Almost all high value scams are made up of multiple smaller transactions,” the PSR explains, “reducing the effectiveness of transaction limits as a tool to manage exposure.”
The reduced cap makes a big difference on multiple levels. For financial institutions and payment service providers (PSPs), the lower limit means they’re less exposed to high-value claims. The reduced exposure to unlimited high-value claims has the potential to lower compliance and operational costs, while the £85,000 cap aligns with the Financial Services Compensation Scheme (FSCS) threshold, creating broader consistency across financial redress schemes.
There are naturally downsides to the lower limit, with critics highlighting significant financial shortfalls for victims of high-value fraud. The lower cap may reduce public confidence in the financial system’s ability to protect against fraud, particularly for those handling large sums of money, while small businesses, many of which often deal with large transaction amounts, may find the cap insufficient to cover losses.
The impact on PSPs and their customers
With PSPs responsible for APP fraud reimbursement, institutions need to take the next step when it comes to fraud detection and prevention to minimise exposure to claims within the £85,000 cap. Customers of all types are likely to benefit from more robust security as a result.
The Financial Conduct Authority’s (FCA’s) recommendations include strengthening controls during onboarding, improving transaction monitoring to detect suspicious activity, and optimising reporting mechanisms to enable swift action. Such controls are largely in line with the PSR’s own recommendations, with the institution setting out a number of steps in its final policy statement in December 2023 to mitigate APP scam risks.
These include setting appropriate transaction limits, improving ‘know your customer’ controls, strengthening transaction-monitoring systems and stopping or freezing payments that PSPs consider to be suspicious for further investigation.
All these measures will invariably improve consumer experience, increasing customers’ confidence to transact online safely, as well as giving them peace of mind with quicker reimbursement in case things go awry.
Going beyond the APP fraud mandate
If the PSR’s mandate can steer financial institutions towards implementing more robust security practices, it can only be a good thing. It’s not the only tool that’s shaping the financial security landscape, however.
In October 2024, the UK government introduced new legislation granting banks enhanced powers to combat fraud. An optional £100 excess on fraud claims has been introduced to encourage customer caution and combat moral hazards, while the Treasury has strengthened prevention measures by handing out new powers to high street banks to delay and investigate payments suspected of being fraudulent by 3 days. The extended processing time for suspicious payments may lead to delays in legitimate transactions, making transparent communication and robust safeguards essential to maintain consumer trust.
Further collaborative efforts, such as Meta’s partnership with UK banks through the Fraud Intelligence Reciprocal Exchange (FIRE) program, can also aid the fight against fraud. Thanks to direct intelligence sharing between financial institutions and the world’s biggest social media platform, FIRE enhances the detection and removal of fraudulent accounts across platforms such as Facebook and Instagram, not only disrupting scam operations, but also fostering a safer digital environment for users. The early stages of the pilot have led to action against thousands of scammer-operated accounts, with approximately 20,000 accounts removed based on shared data.
Additionally, education and awareness are crucial measures to protect consumers against APP fraud. Several high street banks have upgraded their banking channels to share timely content about the signs of potential scams, with increased public awareness helping consumers identify and avoid fraudulent schemes.
Improvements in policing strategies are also significantly contributing to the mitigation of APP fraud. Specialized fraud units within police forces have enhanced the precision and efficiency of investigations. The City of London Police and the National Fraud Intelligence Bureau are upgrading the technology for Action Fraud, providing victims with a more accessible and customer-friendly service. Collaborative efforts among police, banks, and telecommunications firms, exemplified by the work of the Dedicated Card and Payment Crime Unit (DCPCU), have enabled the swift exchange of information, facilitating the prompt apprehension of scammers.
How AI is expected to change the landscape
The coming months will be critical in assessing these changes, as institutions, businesses and the UK government work together to shape security against fraud in the ever-changing world of finance.
While fraud is a terrifyingly big business, it’s only likely to increase with the evolution of AI, making it even more critical that such changes are effective. According to PwC, “There is a real risk that hard-fought improvements in fraud defences could be undone if the right measures are not put in place to defend against fraud in an AI-enabled world.”
Chatbots can be used as part of phishing scams, for example, and AI systems can already read text and reproduce sampled voices, making it possible to send messages from “relatives” whose voices have been spoofed in a similar manner to deepfakes.
Along with other innovations, tools and collaborations, however, the APP fraud mandate, UK legislation and FIRE can all contribute towards redressing such technological advances. Together, this can give financial institutions a much-needed boost in the fight against fraud, providing a more secure future for customers.
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Business
Why Resilience Is Replacing Prevention as the Defining Cybersecurity Strategy
by Manuel Sanchez, Information Security and Compliance Specialist, iManage
For decades, cybersecurity centered around prevention. Build the right walls around your perimeter, deploy the right tools, train your people not to click the wrong links, and you could keep the bad actors out.
Today, the question driving security strategy is no longer “how do we stop a breach?” but “how do we survive one?” It is a subtle but profound shift in philosophy, and it is reshaping everything from how IT and Security leaders structure their teams to how they select their vendors and deploy AI.
Rehearsing for the worst
The practical expression of this shift is visible in how security teams are being restructured. Organisations are establishing dedicated disaster recovery teams – not to prevent incidents, but to contain and recover from them when they occur. These teams maintain detailed, regularly updated playbooks covering everything from backup restoration to stakeholder communications, with roles pre-assigned and procedures rehearsed well in advance.
In many ways, this mirrors the logic behind disaster drills: fire alarms matter, but knowing the evacuation routes and the post-incident recovery plan determines how well an organisation survives. Critically, responsibility cannot rest with the CISO alone. Business continuity after a cyber incident is a whole-company challenge – which means every core part of the organisation is involved to sustain critical business operations.
Governance in the gray areas
Running alongside this shift is a governance crisis that is easy to underestimate until it becomes a serious risk. As organisations adopt more applications across more vendors and hosting services, the shared responsibility model that was supposed to keep cloud accountability clear has become increasingly difficult to enforce.
The sheer volume of cloud applications in use at any given enterprise is too vast for consistent governance under current approaches – and bad actors have become skilled at identifying exactly where vendor responsibility ends, and customer accountability begins, then operating precisely in that “gray area”. Being aware of this risk and putting preventative measures in place is important, but recognising the role these cloud applications play and the impact to key business operations if these applications were compromised, is critical.
Meanwhile, data volumes continue to grow exponentially, and unstructured data continues to accumulate in the background across many digital systems. Why is this important? If you don’t know what data you have, where it is stored, who has access to it, and, most importantly, how it is protected – onsite or cloud backup – this makes the recovery process a lot harder.
AI agents on the rise – and with it new risks
Although the focus of this article is on resilience, prevention must still remain an essential part of your defences. On that front, the accelerating adoption of autonomous AI in cyber defence tasks is reshaping security operations as visibly as anything else happening in the field right now. The volume, speed, and sophistication of modern threats have simply outpaced what human analysts can manage in real time.
The shift is toward AI that doesn’t just flag anomalies for human review, but actively detects, analyses, and neutralises threats as they emerge, even using predictive models to anticipate attacks before they fully materialise. This frees human experts to focus on strategic decisions and complex defence work rather than spending their days firefighting.
Autonomous AI does, however, introduce risks of its own. When AI agents operate across systems – accessing sensitive repositories, triggering actions, sharing data – they expand the attack surface in ways that aren’t always immediately visible.
Managing the digital identities of AI agents, much like managing employee access credentials, is becoming a critical security discipline. Accordingly, comprehensive traceability frameworks that log every action an agent takes are no longer optional; they are the foundation of responsible AI deployment in any security context.
The supply chain wake-up call
The case for moving from a “prevention” mindset to a “resilience” one is further bolstered by recent high-profile breaches via compromised managed service providers, which have forced a fundamental reset in how organisations evaluate their vendors.
The era of cost-first selection is over. Security credentials, demonstrated through continuous and verifiable evidence, are now non-negotiable for any provider hoping to retain enterprise clients – and what organisations are demanding goes well beyond point-in-time audits. They want real-time visibility into every third-party integration, every software update, and every vendor interaction – including the cloud services the vendors themselves use.
“Trust but verify” has become the operational standard, and providers who cannot demonstrate validated controls and live monitoring are finding themselves out of contention. It is a structural shift that will reshape the vendor landscape considerably — and it is already underway.
A new era demands a new approach
In the end, prevention still matters, but resilience – instilled via the key focus areas above – is what turns disruption into survivable events rather than existential crises. The organisations that are honest about the limits of prevention and embrace the shift towards resilience won’t just better withstand the next wave of attacks – they’ll be differentiating themselves from competitors still clinging to yesterday’s playbook.
Business
Adapting compliance in a fragmented regulatory world
Rasha Abdel Jalil, Director of Financial Crime & Compliance at Eastnets, discusses the operational and strategic shifts needed to stay ahead of regulatory compliance in 2025 and beyond.
As we move through 2025, financial institutions face an unprecedented wave of regulatory change. From the EU’s Digital Operational Resilience Act (DORA) to the UK’s Basel 3.1 rollout and upcoming PSD3, the volume and velocity of new requirements are constantly reshaping how banks operate.
But it’s not just the sheer number of regulations that’s creating pressure. It’s the fragmentation and unpredictability. Jurisdictions are moving at different speeds, with overlapping deadlines and shifting expectations. Regulators are tightening controls, accelerating timelines and increasing penalties for non-compliance. And for financial compliance teams, it means navigating a landscape where the goalposts are constantly shifting.
Financial institutions must now strike a delicate balance: staying agile enough to respond to rapid regulatory shifts, while making sure their compliance frameworks are robust, scalable and future-ready.
The new regulatory compliance reality
By October of this year, financial institutions will have to navigate a dense cluster of regulatory compliance deadlines, each with its own scope, jurisdictional nuance and operational impact. From updated Common Reporting Standard (CRS) obligations, which applies to over 100 countries around the world, to Australia’s new Prudential Standard (CPS) 230 on operational risk, the scope of change is both global and granular.
Layered on top are sweeping EU regulations like the AI Act and the Instant Payments Regulation, the latter coming into force in October. These frameworks introduce new rules and redefine how institutions must manage data, risk and operational resilience, forcing financial compliance teams to juggle multiple reporting and governance requirements. A notable development is Verification of Payee (VOP), which adds a crucial layer of fraud protection for instant payments. This directly aligns with the regulator’s focus on instant payment security and compliance.
The result is a compliance environment that’s increasingly fragmented and unforgiving. In fact, 75% of compliance decision makers in Europe’s financial services sector agree that regulatory demands on their compliance teams have significantly increased over the past year. To put it simply, many are struggling to keep pace with regulatory change.
But why is it so difficult for teams to adapt?
The answer lies in a perfect storm of structural and operational challenges. In many organisations, compliance data is trapped in silos spread across departments, jurisdictions and legacy platforms. Traditional approaches – built around periodic reviews, static controls and manual processes – are no longer fit for purpose. Yet despite mounting pressure, many teams face internal resistance to changing established ways of working, which further slows progress and reinforces outdated models. Meanwhile, the pace of regulatory change continues to accelerate, customer expectations are rising and geopolitical uncertainty adds further complexity.
At the same time, institutions are facing a growing compliance talent gap. As regulatory expectations become more complex, the skills required to manage them are evolving. Yet many firms are struggling to find and retain professionals with the right mix of legal, technical and operational expertise. Experienced professionals are retiring en-masse, while nearly half of the new entrants lack the right experience needed to step into these roles effectively. And as AI tools become more central to investigative and decision-making processes, the need for technical fluency within compliance teams is growing faster than organisations can upskill. This shortage is leaving compliance teams overstretched, under-resourced and increasingly reliant on outdated tools and processes.
Therefore, in this changing environment, the question suddenly becomes how can institutions adapt?
Staying compliant in a shifting landscape
The pressure to adapt is real, but so is the opportunity. Institutions that reframe compliance as a proactive, technology-driven capability can build a more resilient and responsive foundation that’s now essential to staying ahead of regulatory change.
This begins with real-time visibility. As regulatory timelines change and expectations rise, institutions need systems that can surface compliance risks as they emerge, not weeks or months later. This means adopting tools that provide continuous monitoring, automated alerts and dynamic reporting.
But visibility alone isn’t enough. To act on insights effectively, institutions also need interoperability – the ability to unify data from across departments, jurisdictions and platforms. A modern compliance architecture must consolidate inputs from siloed systems into a unified case manager to support cross-regulatory reporting and governance. This not only improves accuracy and efficiency but also allows for faster, more coordinated responses to regulatory change.
To manage growing complexity at scale, many institutions are now turning to AI-powered compliance tools. Traditional rules-based systems often struggle to distinguish between suspicious and benign activity, leading to high false positive rates and operational inefficiencies. AI, by contrast, can learn from historical data to detect subtle anomalies, adapt to evolving fraud tactics and prioritise high-risk alerts with greater precision.
When layered with alert triage capabilities, AI can intelligently suppress low-value alerts and false positives, freeing up human investigators to focus on genuinely suspicious activity. At the more advanced stages, deep learning models can detect behavioural changes and suspicious network clusters, providing a multi-dimensional view of risk that static systems simply can’t match.
Of course, transparency and explainability in AI models are crucial. With regulations like the EU AI Act mandating interpretability in AI-driven decisions, institutions must make sure that every alert or action taken by an AI system is auditable and understandable. This includes clear justifications, visual tools such as link analysis, and detailed logs that support human oversight.
Alongside AI, automation continues to play a key role in modern compliance strategies. Automated sanction screening tools and watchlist screening, for example, help institutions maintain consistency and accuracy across jurisdictions, especially as global lists evolve in response to geopolitical events.
Similarly, customisable regulatory reporting tools, powered by automation, allow compliance teams to adapt to shifting requirements under various frameworks. One example is the upcoming enforcement of ISO 20022, which introduces a global standard for payment messaging. Its structured data format demands upgraded systems and more precise compliance screening, making automation and data interoperability more critical than ever.
This is particularly important in light of the ongoing talent shortages across the sector. With newer entrants still building the necessary expertise, automation and AI can help bridge the gap and allow teams to focus on complex tasks instead.
The future of compliance
As the regulatory compliance landscape becomes more fragmented, compliance can no longer be treated as a tick-box exercise. It must evolve into a dynamic, intelligence-led capability, one that allows institutions to respond to change, manage risk proactively and operate with confidence across jurisdictions.
To achieve this, institutions must rethink how compliance is structured, resourced and embedded into the fabric of financial operations. Those that do, and use the right tools in the process, will be better positioned to meet the demands of regulators today and in the future.
Business
Why Shorter SSL/TLS Certificate Lifespans Are the Perfect Wake-Up Call for CIOs
By Tim Callan, Chief Compliance Officer at Sectigo and Vice-Chair of the CA/Browser Forum
Let’s be honest: AI has been the headline act this year. It’s the rockstar of boardroom conversations and LinkedIn thought leadership. But while AI commands the spotlight, quantum computing is quietly tuning its instruments backstage. And when it steps forward, it won’t be playing backup. For CIOs, the smart move isn’t just watching the main stage — it’s preparing proactively for the moment quantum takes center stage and rewrites the rules of data protection.
Quantum computing is no longer a distant science project. NIST has already published standards for quantum-resistant algorithms and set a clear deadline: RSA and ECC, the cryptographic algorithms that protect today’s data, must be deprecated by 2030. We’re no longer talking about “forecasts;” we are talking about actual directives from government organizations to implement change. And yet, many organizations are still treating this like a future problem. The reality is that threat actors aren’t waiting. They’re collecting encrypted data now, knowing they’ll be able to decrypt it later. If we wait until quantum machines are commercially viable, we’ll be too late. The time to prepare is before the clock runs out and, unfortunately, that clock is already ticking.
For CIOs, this is an infrastructure and risk management crisis in the making. If your organization’s cryptographic infrastructure isn’t agile enough to adapt, the integrity of your digital operations and the trust they rely on could very soon be compromised.
The Quantum Threat Is Already Here
Quantum computing’s potential to disrupt global systems and the data that runs through it is not hypothetical. Attackers are already engaging in “Harvest Now, Decrypt Later” (HNDL) strategies, intercepting encrypted data today with the intent to decrypt it once quantum capabilities mature.
Recent research found that an alarming 60% of organizations are very or extremely concerned about HNDL attacks, and 59% express similar concern about “Trust Now, Forge Later” threats, where adversaries steal digitally signed documents to forge them in the future.
Despite this awareness, only 14% of organizations have conducted a full assessment of systems vulnerable to quantum attacks. Nearly half (43%) of organizations are still in a “wait and see” mode. For CIOs, this gap highlights the need for leadership: it’s not
enough to know the risks exist, you must identify which systems, applications, and data flows will still be sensitive in ten or twenty years and prioritize them for PQC migration.
Crypto Agility Is a Data Leadership Imperative
Crypto agility (the ability to rapidly identify, manage, and replace cryptographic assets) is now a core competency for IT leaders to ensure business continuity, compliance, and trust. The most immediate pressure point is SSL/TLS certificates. These certificates authenticate digital identities and secure communications across data pipelines, APIs, and partner integrations.
The CA/Browser Forum has mandated a phased reduction in certificate lifespans from 398 days today to just 47 days by 2029. The first milestone arrives in March 2026, when certificates must be renewed every six months, shrinking to near-monthly by 2029.
For CIOs, it’s not just an operational housekeeping issue. Every expired or mismanaged certificate is a potential data outage. That means application downtimes, broken integration, failed transactions and compliance violations. With less than 1 in 5 organizations prepared for monthly renewals, and only 5% fully automating their certificate management processes currently, most enterprises face serious continuity and trust risks.
The upside? Preparing for shortened certificate lifespans directly supports quantum readiness. Ninety percent of organizations recognize the overlap between certificate agility and post-quantum cryptography preparedness. By investing in automation now, CIOs can ensure uninterrupted operations today while laying a scalable foundation for future-proof cryptographic governance.
The Strategic Imperative of PQC Migration
Migrating to quantum-safe algorithms is not a plug-and-play upgrade. It’s a full-scale transformation. Ninety-eight percent of organizations expect challenges, with top barriers including system complexity, lack of expertise, and cross-team coordination. Legacy systems (many with hardcoded cryptographic functions) make this even harder.
That’s why establishing a Center of Cryptographic Excellence (CryptoCOE) is a critical first step. A CryptoCOE centralizes governance, aligns stakeholders, and drives execution. According to Gartner, by 2028 organizations with a CryptoCOE will save 50% of costs in their PQC transition compared to those without.
For CIOs, this is a natural extension of your role. Cryptography touches every layer of enterprise infrastructure. A CryptoCOE ensures that cryptographic decisions are made with full visibility into system dependencies, risk profiles and regulatory obligations.
By championing crypto agility as an infrastructure priority, CIOs can transform PQC migration from a technical project into a strategic initiative that protects the organization’s most critical assets.
The Road Ahead
The shift to 47-day certificates is a wake-up call. It marks the end of static cryptography and the beginning of a dynamic, agile era. Organizations that embrace this change will not only avoid outages and compliance failures, but they’ll be also prepared for the quantum future.
Crypto agility is both a technical capability and a leadership mandate. For CIOs, the path forward to quantum-resistant infrastructure can be clear: invest in automation, build cross-functional alignment, and treat cryptographic governance as a core pillar of enterprise resilience.
Why Resilience Is Replacing Prevention as the Defining Cybersecurity Strategy
Adapting compliance in a fragmented regulatory world
Why Shorter SSL/TLS Certificate Lifespans Are the Perfect Wake-Up Call for CIOs
How 5G and AI are shaping the future of eHealth
Combating Cyber Fraud in the Aviation Industry
