APP fraud victims to get mandatory reimbursement rights under new PSR rules

This measure fails to get to the root of the problem which is banks struggling to detect the accounts fraudsters use to collect fraud and divert funds and then failing to block onward transmission of the funds. It's baffling why so little is said or done about this and whether some banks are worse than others at managing it (which fraud stats suggest is the case).

Reimbursement for victims is necessary and a good optic to show action is being taken but it will have no direct impact on fraudsters - it might even lead to APP reimbursement fraud.

Faster Payment participation, either direct or indirect should be conditional on providing an up to standard Confirmation of Payee service.

Paying anyone who fails the CoP check could then at least be the 'exceptional circumstance' where reimbursement is not made.

PayUK real-time transaction monitoring to identify accounts with non standard activity linked to an enhanced CoP validation warning informed by that unusual activity would help.

As with safeguarding children, Data Protection should never a barrier to sharing data and concerns between banks/PayUK about individuals, to protect the vulnerable. Banking confidentiality needs to move with the times. Confirming the standing of your customer was never something that banks didn't do although Bank references became meaningless due to the fact that Banks didn't know much about the standing of their customers who had become just numbers to them. 'References' for payees need to go real-time (based on account data) and payment system design needs to incorporate fraud prevention as well as speed and messaging standards.

All elements of the transaction, not just the remitter, have a responsibility and a part to play to prevent the billions being lost to financial crime whether reimbursed or not.