FOS decisions / Authorised Push Payment (APP) Scam
Authorised Push Payment (APP) Scam
Financial Ombudsman Service final decisions, reproduced verbatim from the FOS published decisions register.
Decisions
252
Upheld
134
Not upheld
118
Avg redress
£27,913
Upheld complaints (107)
Wise Payments Limited
DRN-6196864Under the Payment Services Regulations 2017, a payment is unauthorised if the account holder did not make it themselves or give permission for it, and the provider is responsible for refunding unauthorised payments unless the consumer was g
UpheldRedress £154Apr 2026Santander UK Plc
DRN-6265300Banks must monitor account activity for unusual transactions and take reasonable steps to protect customers from apparent fraud risks, including intervention before processing suspicious payments.
UpheldMar 2026Starling Bank Limited
DRN-6260702A bank signatory to the Contingent Reimbursement Model Code must reimburse victims of Authorised Push Payment scams unless specific exemptions apply, and the bank's failure to intervene pre-payment does not excuse liability where the scam w
UpheldRedress £20,000Mar 2026Currensea Limited
DRN-5771664Under the Payment Services Regulations 2017, a payment service provider must refund unauthorised payments unless the consumer failed with intent or gross negligence to keep secure information safe.
UpheldMar 2026Wise Payments Limited
DRN-6259855A payment service provider must reimburse unauthorized payments unless the consumer failed to keep their security credentials safe with gross negligence or acted fraudulently.
UpheldMar 2026Metro Bank Plc
DRN-6256064Banks must provide meaningful, targeted risk-based intervention when customers make unusual international payments that display characteristics of investment scams, in accordance with the Payment Services Regulations 2017 and the FCA's Cons
UpheldMar 2026Revolut Ltd
DRN-6162600An EMI should intervene and warn customers when transaction patterns indicate heightened fraud risk, particularly for cryptocurrency-related payments.
UpheldMar 2026Wise Payments Limited
DRN-6260685Firms must implement proportionate fraud prevention measures and scam warnings tailored to identifiable risks, particularly for cryptocurrency payments, to avoid foreseeable harm under the FCA's Consumer Duty.
UpheldMar 2026Barclays Bank UK PLC
DRN-6256148Banks have a contractual right to refuse payment instructions or delay them to investigate suspected fraud, and good practice requires them to exercise reasonable vigilance for signs of APP scams even where not legally obligated to do so.
UpheldRedress £16,200Mar 2026Wise Payments Limited
DRN-6246686Payment service providers must intervene with human checks on unusually large international payments from new accounts to protect customers from scams, even though customers are presumed liable for authorised payments.
UpheldRedress £10,000Mar 2026Santander UK Plc
DRN-6264141Payment service providers should reimburse victims of authorised push payment scams under the CRM Code unless limited exceptions apply, including where the customer lacked a reasonable basis for belief in the payee's legitimacy.
UpheldMar 2026HSBC UK Bank Plc
DRN-6225943Under the Faster Payment Scheme Reimbursement Rules, a bank must reimburse an APP scam victim where deception caused the payment to be made for a purpose other than intended, particularly if the victim is a vulnerable consumer.
UpheldRedress £6,065Feb 2026Revolut Ltd
DRN-6183059An Electronic Money Institution must take reasonable steps to identify and intervene in suspicious payment patterns that demonstrate hallmarks of fraud, even for new customers.
UpheldFeb 2026Barclays Bank UK PLC
DRN-6200201Compensatory interest on refunded amounts in scam cases should be calculated from the date of each individual payment to the date of settlement, not from the date of the final transaction or claim logging.
UpheldFeb 2026Monzo Bank Ltd
DRN-5816462Banks must intervene with tailored warnings when payment patterns suggest APP scam activity, and liability for losses should be shared where the bank fails to intervene despite clear warning signs.
UpheldFeb 2026ClearBank Limited
DRN-5631437A bank may fairly reimburse a customer for authorised payments made as a result of fraud when the bank missed opportunities to intervene through additional checks.
UpheldFeb 2026The Royal Bank of Scotland Plc
DRN-6141203Banks must take appropriate steps to intervene and protect vulnerable customers from investment scams when warning signs are present.
UpheldFeb 2026Bank of Scotland plc trading as Halifax
DRN-6161835A firm signed up to the Contingent Reimbursement Model Code must reimburse an authorised push payment scam victim unless it can establish the customer made the payment without a reasonable basis for belief in the payee's legitimacy or had a
UpheldFeb 2026HSBC UK Bank Plc
DRN-6149112Banks should monitor accounts for unusual transactions and take additional steps to prevent scams, irrespective of customer authorization, particularly when patterns suggest potential fraud.
UpheldJan 2026Santander UK Plc
DRN-6190711Banks must intervene to prevent APP scams where they have reasonable grounds to suspect fraud, even when the customer has authorized the payment.
UpheldJan 2026Santander UK Plc
DRN-6124152A bank should intervene and question suspicious transactions to prevent authorised push payment scams, and bears responsibility for losses that could have been prevented by effective earlier intervention.
UpheldJan 2026Revolut Ltd
DRN-6160017Payment Service Providers must monitor accounts for signs of fraud and scams, intervening with additional checks or warnings on high-risk transactions such as cryptocurrency payments, even where the customer has authorised the transaction.
UpheldJan 2026Nationwide Building Society
DRN-6121374A bank signatory to the Contingent Reimbursement Model Code should reimburse customers who make payments as a result of APP Scams unless specific exceptions apply, and banks should exercise due diligence when customers make unusually large
UpheldJan 2026Wise Payments Limited
DRN-6130712Payment service providers must exercise reasonable care to identify and intervene in potentially fraudulent transactions, particularly when payment patterns show unusual escalation and characteristics inconsistent with the customer's normal
UpheldJan 2026ClearBank Limited
DRN-6114787A payment can be fairly considered authorised if confirmed by the customer in their banking app through stronger authentication, even if the customer was manipulated by a scammer into doing so.
UpheldJan 2026Nationwide Building Society
DRN-6125264Firms must act fairly and reasonably to protect customers from fraud, but customers remain liable for authorised payments unless covered by the Contingent Reimbursement Model Code.
UpheldRedress £59,000Jan 2026HSBC UK Bank Plc
DRN-6131134Banks must reimburse victims of Authorised Push Payment scams under the CRM Code unless specific exemptions apply, and cannot dismiss claims as mere civil disputes without proper investigation.
UpheldRedress £20,000Dec 2025HSBC Bank UK Plc
DRN-6062978Banks should reimburse customers who fall victim to Authorised Push Payment scams under the CRM Code, even where sophisticated fraud is involved, if the customer genuinely believed the payment was for legitimate purposes.
UpheldRedress £115,000Dec 2025HSBC Bank UK Plc
DRN-6133402A bank should reimburse a customer under the CRM Code for an Authorised Push Payment where the customer transferred funds believing they were for legitimate purposes but which were actually fraudulent, even if sophisticated due diligence wa
UpheldRedress £80,000Dec 2025HSBC Bank UK Plc
DRN-6135793Banks must reimburse customers for Authorised Push Payment scams under the CRM Code when the customer believed the payment was for legitimate purposes but it was actually fraudulent.
UpheldDec 2025HSBC Bank UK Plc
DRN-6135070A bank that is a signatory to the CRM Code must assess APP Scam claims on their merits rather than dismissing them as private civil disputes without proper investigation.
UpheldDec 2025Barclays Bank UK PLC
DRN-6052847Banks must reimburse customers for authorised payments made in response to scams under the CRM Code, except where the customer exhibited gross negligence or the bank had reasonable grounds to believe the payment was for a legitimate purpose
UpheldNov 2025HSBC UK Bank Plc
DRN-5978418Banks must make reasonable fraud checks on transactions according to regulatory expectations and good industry practice, and where they fail to do so, they may share responsibility with the consumer based on contributory negligence.
UpheldRedress £1,600Oct 2025Revolut Ltd
DRN-5830629An account holder is normally only responsible for payments they have authorised, but authorisation can be given through permission for others to make payments on their behalf, even if the account holder has been deceived by a scam.
UpheldSept 2025Starling Bank Limited
DRN-5810776Banks must monitor accounts for unusual transactions and intervene proportionately to prevent customers suffering financial harm from fraud, even where payments are customer-authorised.
UpheldAug 2025NATIONAL WESTMINSTER BANK PUBLIC LIMITED COMPANY
DRN-5314565Payment service providers should monitor customer accounts for fraud and scam risks, and intervene when transaction patterns present a material risk of financial harm.
UpheldAug 2025Wise Payments Limited
DRN-5258267Electronic money institutions must take steps to keep customer accounts safe by looking out for payments indicating risk of fraud and intervening where appropriate.
UpheldRedress £113,994Dec 2024Currensea Limited
DRN-6270400Payment service providers cannot hold account holders liable for unauthorised payments made via distance contracts under the Payment Services Regulations 2017, even if the account holder shared security credentials following a scam.
UpheldRedress £1,776HSBC UK Bank
DRN-6212636A bank signatory to the CRM Code must reimburse victims of authorised push payment scams on the balance of probabilities, even while external investigations are ongoing, unless a specific exemption applies.
UpheldRedress £20,000Starling Bank Limited
DRN-6088480Under the Contingent Reimbursement Model Code, firms must reimburse scam victims unless they can establish the customer ignored effective warnings or lacked reasonable basis for belief in the transaction's legitimacy.
UpheldHSBC UK Bank Plc
DRN-5837840A bank signatory to the CRM Code should reimburse a victim of an APP scam unless limited exceptions apply, and a police investigation does not prevent the ombudsman from assessing the complaint.
UpheldRedress £35,000HSBC UK Bank Plc
DRN-5837809A bank signatory to the CRM Code must reimburse customers who are victims of authorised push payment (APP) scams except in limited circumstances, and cannot indefinitely pause a decision pending police investigation.
UpheldRedress £25,000Nationwide Building Society
DRN-5810828A financial institution must take reasonable steps to protect customers from authorised push payment fraud and should have intervened when transaction patterns suggested the customer was likely being scammed.
UpheldBank of Scotland PLC
DRN-5746207A firm may decline APP scam reimbursement under the CRM Code if the customer failed to act with reasonable care, unless the customer is considered vulnerable under the specific CRM definition.
UpheldRedress £500Nationwide Building Society
DRN-5651786A financial institution may be liable for losses from investment scams where it could have intervened through warnings or contact, but contributory negligence should not be applied to reduce compensation when the consumer was targeted by a
UpheldRedress £13,500Revolut Ltd
DRN-5237433A payment service provider has a fair and reasonable obligation to monitor accounts and intervene in potentially fraudulent transactions, particularly where there are signs of multi-stage cryptocurrency scams.
UpheldRedress £10,300HSBC UK Bank Plc
DRN-5815261Payment Service Providers can be liable for APP scam losses outside statutory reimbursement rules where they fail to provide adequate warnings that would have prevented the fraud.
UpheldRedress £54,100Zempler Bank Limited
DRN-6124260Under the Payment Services Regulations 2017, a payment can be considered authorised where a customer completes in-app authentication, even if induced by a scammer, provided the authentication screens clearly presented payment details and ap
UpheldRedress £24,000Northern Bank Limited
DRN-6002210Banks must intervene when payments are unusual or suspicious enough to reasonably suggest fraud risk, balancing fraud prevention against customer service disruption.
UpheldRedress £5,214HSBC UK Bank Plc
DRN-5536106Banks must identify and prevent sufficiently unusual or uncharacteristic payments to protect customers from fraud, particularly where cryptocurrency purchases are involved.
UpheldBarclays Bank UK PLC
DRN-6210790Banks must intervene on large cryptocurrency payments where fraud risk is heightened, but consumers bear partial responsibility for losses from investment scams.
UpheldRedress £5,000Monzo Bank Ltd
DRN-6158141A bank must intervene where it identifies substantial payments indicating risk of financial harm from known scam types, particularly cryptocurrency investments.
UpheldMetro Bank PLC
DRN-6256178Banks must intervene with probing questions when customers make large cryptocurrency payments, as such transactions carry elevated scam risk.
UpheldHSBC UK Bank Plc
DRN-6028956Under the CRM Code, a firm must reimburse APP scam victims unless the customer was deceived into transferring funds for fraudulent purposes that differed from their believed legitimate purpose.
UpheldRedress £5,500HSBC UK Bank Plc
DRN-5833388Under the CRM code, firms must reimburse customers who are victims of scams except in limited circumstances, and this assessment can be made on the balance of probabilities without waiting for criminal investigations to conclude.
UpheldRedress £13,500HSBC UK Bank Plc
DRN-6158143Banks must intervene when customers make payments to cryptocurrency exchanges, but consumers share responsibility when they fail to conduct basic due diligence checks before transferring substantial sums.
UpheldBarclays Bank UK PLC
DRN-6027745Banks must monitor accounts for unusual transactions indicative of fraud and scams, and take additional steps or warnings before processing payments where appropriate, particularly for cryptocurrency-related transactions.
UpheldHSBC UK Bank Plc
DRN-5931199A bank signatory to the CRM code must reimburse customers who are victims of scams as defined in the code, even though the customer authorized the payment.
UpheldRedress £28,000Bank of Scotland plc trading as Halifax
DRN-6026617A bank should intervene on suspicious cryptocurrency payments when the circumstances indicate potential fraud, even when funds are sent to an account in the customer's own name.
UpheldRevolut Ltd
DRN-5255906An EMI must balance its contractual duty to process authorised payments with a fair and reasonable obligation to implement proportionate fraud prevention measures and intervene where payments appear suspicious.
UpheldHSBC UK Bank Plc
DRN-6054384Payment Service Providers must reimburse APP scam victims within defined timeframes under the Reimbursement Rules and cannot delay decisions pending police investigations.
UpheldRedress £13,000HSBC UK Bank Plc
DRN-6022991A firm signed up to the CRM Code should reimburse a customer who is the victim of an APP scam unless limited exceptions apply, and it is appropriate to determine such complaints based on available evidence rather than waiting for ongoing ex
UpheldRedress £20,000HSBC UK Bank Plc
DRN-5639007Banks must reimburse customers for authorised push payment fraud under the CRM Code unless they can rely on a valid exception, which requires an effective warning and the customer's failure to take reasonable care.
UpheldRedress £142,000eToro Money UK Ltd
DRN-6263492A firm must take reasonable steps to identify and warn customers about unusual payment patterns that may indicate fraud risk, even when a payment is technically authorised.
UpheldRedress £100PSI-Pay Ltd
DRN-5978544An EMI must take reasonable care to organise its affairs responsibly and effectively with adequate risk management systems, and must avoid causing foreseeable harm to customers by having inadequate systems to detect and prevent scams.
UpheldRedress £605Santander UK Plc
DRN-6229349A bank should intervene to prevent fraud when presented with warning signs such as rapid successive payments for gift cards, even if the consumer bears some responsibility for their own lack of caution.
UpheldRedress £950Bank of Scotland plc trading as Halifax
DRN-5934212Payment services providers must monitor accounts for fraud risk and intervene proportionately before payments are made, even when the reimbursement rules cap is met.
UpheldRedress £25,100Barclays Bank UK PLC
DRN-5596350A bank may be responsible for refunding authorised payments if it fails to carry out adequate checks to protect customers from investment scams, with liability apportioned based on the customer's own due diligence.
UpheldRedress £8,350Bank of Scotland plc
DRN-5679899Banks may be expected to take additional steps to protect customers from fraud through further checks before processing payments, even when customers have authorized the transactions.
UpheldCaxton Payments Limited
DRN-5701497Firms should take reasonable steps to identify and warn customers of potential fraud or scams where payment patterns are unusual, even when the customer has authorised the payment.
UpheldRedress £10,459Starling Bank Limited
DRN-6056145Under the FPS Reimbursement Rules, a payment service provider must reimburse APP scam payments made by vulnerable consumers regardless of whether the consumer failed to exercise caution.
UpheldRedress £8,417Lloyds Bank PLC
DRN-5827919Banks must reimburse customers who are victims of APP scams under the CRM Code, unless specific exceptions apply, and a scam exists where a fraudster acts with dishonest deception rather than a genuine business failing.
UpheldRevolut Ltd
DRN-5855004Payment service providers are liable for unauthorised payments unless the customer authorised them, even if obtained through deception, but customer shares responsibility where they actively confirmed payments despite warnings.
UpheldRedress £2,625HSBC UK Bank Plc
DRN-5814892A bank's obligation under the Contingent Reimbursement Model Code to reimburse APP Scam victims depends on whether the consumer exercised appropriate care in executing the payment.
UpheldRevolut Ltd
DRN-5249545Electronic Money Institutions must monitor accounts for unusual transactions and take additional steps to prevent fraud, particularly in cryptocurrency scams.
UpheldCurrensea Limited
DRN-5819741Payment service providers cannot hold account holders responsible for unauthorised payments made via distance contracts unless the account holder is proven to have authorised the transaction themselves.
UpheldRedress £450Monzo Bank Ltd
DRN-6210020A bank should intervene to prevent payment fraud when it identifies unusual and out-of-character transaction patterns that indicate a customer may be at risk of financial harm.
UpheldHSBC UK Bank Plc
DRN-5974730Banks cannot indefinitely defer APP scam reimbursement decisions under the CRM Code merely by awaiting external regulatory investigations when sufficient evidence of scam intent already exists.
UpheldRedress £20,000Metro Bank PLC
DRN-6230411Under the CRM Code, firms must reimburse customers vulnerable to APP scams unless specific exceptions apply, and vulnerability assessments must consider the customer's circumstances at the time of the scam.
UpheldRedress £48,000Santander UK Plc
DRN-5941186Under the Contingent Reimbursement Model (CRM) Code, a customer is entitled to reimbursement for APP scam losses even when funds are transferred to an intermediary that is FCA authorised, provided the customer lost control of funds for frau
UpheldRedress £20,000NATIONAL WESTMINSTER BANK PUBLIC LIMITED COMPANY
DRN-6254520Payment service providers are only responsible for reimbursing authorised push payments made to accounts not under the consumer's control under the Faster Payments Scheme Reimbursement Rules; customers bear responsibility for other payments
UpheldRedress £134Starling Bank Limited
DRN-6196821A bank may be held responsible for reimbursing an authorised payment made as a result of an APP scam, even where the payment was sent to a genuine regulated intermediary, if the underlying investment was itself a scam.
UpheldRedress £14,530HSBC UK Bank PLC
DRN-5982263Banks must reimburse victims of Authorised Push Payment scams under the CRM Code unless limited exceptions apply, and cannot delay decisions pending criminal proceedings.
UpheldHSBC UK Bank Plc
DRN-5939271Banks signed up to the Contingent Reimbursement Model Code must reimburse victims of Authorised Push Payment scams unless specific exemptions apply, and fairness does not require delaying determination pending criminal investigations when s
UpheldStarling Bank Limited
DRN-6027659Under the CRM Code, firms must reimburse victims of APP scams unless the customer ignored an effective warning or lacked a reasonable basis for belief in the legitimacy of the payee or transaction.
UpheldRedress £13,000National Westminster Bank Public Limited Company
DRN-6240429Banks must reimburse victims of APP scams under the CRM Code unless the transaction constitutes a private civil dispute.
UpheldRedress £144,690Lloyds Bank PLC
DRN-6065885A bank may be required to reimburse a customer for an authorized payment made as a consequence of fraudulent deception, even where the CRM Code's APP scam definition does not apply, if the firm receiving funds had dishonest intentions from
UpheldStarling Bank Limited
DRN-6055365A bank signatory to the CRM Code must reimburse victims of authorised push payment scams unless the bank establishes that the customer ignored an effective warning or lacked a reasonable basis for belief in the payee's legitimacy.
UpheldRedress £5,000Bank of Scotland plc trading as Halifax
DRN-6260544Under the CRM Code, a sending firm may choose not to reimburse a customer for an APP scam if the customer failed to meet their requisite level of care, but the firm must have provided an Effective Warning at the time of the transaction.
UpheldRedress £325Santander UK Plc
DRN-5984590A bank must intervene when a customer's transaction pattern is inconsistent with their normal behaviour and raises scam concerns, even if the customer has been coached by scammers about what to say.
UpheldRedress £500Nationwide Building Society
DRN-6261685Banks must reimburse victims of Authorised Push Payment scams under the CRM Code, except in limited circumstances where the customer failed to meet their requisite level of care.
UpheldMonzo Bank Ltd
DRN-6262572Banks are not liable for authorised payments made by customers to scammers unless the payments were unusual enough to warrant intervention based on the customer's transaction history and regulatory requirements.
UpheldStarling Bank Limited
DRN-5865818A bank signatory to the CRM Code must reimburse a customer who has been the victim of an APP scam unless a limited exception applies, regardless of the level of due diligence conducted by the customer.
UpheldRedress £65,000Lloyds Bank PLC
DRN-5976296Banks must reimburse customers for authorised payments made as a result of APP scams under the CRM Code, unless the customer failed to protect themselves with reasonable care, but vulnerability and the implausibility of the scam narrative m
UpheldRevolut Ltd
DRN-6216856A payment can be treated as authorised where a customer confirms it through a valid authentication process, even if they were deceived about the transaction's purpose.
UpheldRedress £175Santander UK Plc
DRN-5760665Banks should take additional protective steps before processing payments to crypto providers when there is an increased and recognised risk of fraud, even though the consumer has authorised the payment.
UpheldYorkshire Building Society
DRN-5917086Banks must make tailored fraud interventions for unusual or first-time transactions to cryptocurrency platforms, even when initiated by customers to accounts in their own name.
UpheldRedress £348Nationwide Building Society
DRN-6205229A firm must monitor transactions for fraud risk and take protective steps, but is only liable for losses that would not have occurred 'but for' its failing.
UpheldMonzo Bank Ltd
DRN-5304502A bank should intervene to prevent further payments when it becomes aware a customer is likely a victim of an investment scam, and should share liability for losses if it fails to do so.
UpheldHSBC UK Bank Plc
DRN-5771668Under the Contingent Reimbursement Model Code, a firm must reimburse a customer who is the victim of an authorised push payment scam where the customer transferred funds for purposes they believed were legitimate but which were in fact frau
UpheldSantander UK Plc
DRN-6066979A bank is liable under the CRM Code to reimburse authorised push payment scam victims in full unless the customer failed to meet their obligations, including not carrying out checks where the scam was particularly obvious.
UpheldRedress £71,456Santander UK Plc
DRN-5933600A bank should intervene to prevent fraud when payments deviate significantly from a customer's usual spending pattern and the cumulative amount raises suspicious activity concerns.
UpheldNewDay Ltd
DRN-6192358Payment service providers must identify fraud risks and take appropriate action when suspicious transactions are detected, rather than relying solely on cardholder confirmation.
UpheldSantander UK Plc
DRN-6054495A firm signatory to the CRM Code must reimburse customers who are victims of APP scams, except in limited circumstances, and this determination does not require a criminal conviction or police investigation outcome.
UpheldRedress £20,160Revolut Ltd
DRN-6064184Payment institutions must monitor accounts for signs of fraud and scams, and intervene with appropriate warnings when customers show risk of financial harm, particularly in multi-stage crypto investment scams.
UpheldRevolut Ltd
DRN-5890299Payment service providers must intervene when they observe unusual transaction patterns that suggest a customer may be a victim of fraud, even when the customer has technically authorised the payments.
UpheldRedress £21,865Bank of Scotland plc
DRN-6239377Banks must take reasonable steps to warn customers of scam risks proportionate to payment value and type, particularly for crypto transactions, under the Consumer Duty.
Upheld
Not-upheld complaints (93)
Monzo Bank Ltd
DRN-6260769Authorized payment scam losses are the customer's liability unless the bank failed to exercise reasonable care and follow industry best practice standards for identifying vulnerable consumers and detecting suspicious transaction patterns.
Not upheldMar 2026Monzo Bank Ltd
DRN-6174690A bank is not required to intervene and refuse payment authorization when transactions to cryptocurrency platforms, though part of a scam, do not appear unusual relative to the customer's account usage patterns.
Not upheldMar 2026Santander UK Plc
DRN-6259555Authorised push payments made by consumers following successful scams are not covered by chargeback scheme protections, and banks are not obligated to reimburse losses where the consumer authorised the transaction.
Not upheldMar 2026HSBC UK Bank Plc
DRN-6246630A bank is only liable to reimburse authorised payments if they constitute an APP scam under the CRM Code definition, which requires the payee to have acted with fraudulent intent from the outset or early stage.
Not upheldMar 2026Wise Payments Ltd
DRN-6221632Authorised payment services transactions place initial liability on the consumer, but providers may be expected to intervene with additional checks or warnings where heightened scam risks are present.
Not upheldFeb 2026Lloyds Bank PLC
DRN-6266616A bank is not liable for losses from an investment that fails unless it breached its own account opening or monitoring procedures, regardless of whether the investment was a scam.
Not upheldWise Payments Limited
DRN-5907419A firm is only liable to reimburse a customer for an authorised payment if there is sufficient evidence that the payment was obtained through fraud with criminal intent by the recipient.
Not upheldRevolut Ltd
DRN-6267984A payment is authorised under the Payment Services Regulations 2017 if the customer consented to it, regardless of whether they were deceived about the circumstances, and consent does not require informed consent.
Not upheldBank of Scotland plc
DRN-6220434A bank is only required to reimburse an authorised push payment scam under the CRM Code if the recipient's actual purpose was fraudulently different from the customer's understood purpose.
Not upheldHSBC UK Bank
DRN-6062981A bank is only required to reimburse an authorised push payment scam under the CRM Code if the customer was deceived into transferring funds to a different person or for fraudulent purposes, supported by evidence of the recipient's dishones
Not upheldBarclays Bank UK PLC
DRN-6230484Authorised Push Payment scams under the Reimbursement Rules require criminal deception about the payment purpose or recipient identity, whereas civil disputes over service quality or pricing do not qualify for reimbursement.
Not upheldLloyds Bank PLC
DRN-6270782Authorised push payment scams under the CRM Code require proof that the consumer was deceived into transferring funds to a different person or for fraudulent purposes, and do not apply to civil disputes over services not received or defecti
Not upheldLloyds Bank PLC
DRN-6121452A civil dispute between a consumer and a payee for non-delivery of goods or services does not constitute an Authorised Push Payment scam under the FPS Reimbursement Rules unless there is convincing evidence of fraudulent intent at the time
Not upheldBank of Scotland plc
DRN-6224934A firm is not responsible for an APP scam loss unless the consumer can provide convincing evidence demonstrating they were dishonestly deceived about the purpose of the payments, with criminal intent established.
Not upheldBarclays Bank UK PLC
DRN-6107130An authorised push payment only falls within the CRM Code's scope if it meets the definition of an APP scam involving deception about the recipient's identity or fraudulent purpose; a civil dispute over defective goods or services is exclud
Not upheldDecision DRN-6173830
Under the FPS Reimbursement Rules, a PSP may apply an excess to an APP scam claim unless the victim was a Vulnerable Consumer whose vulnerability materially affected their ability to protect themselves from the scam.
Not upheldNATIONAL WESTMINSTER BANK PUBLIC LIMITED COMPANY
DRN-5641808Account providers must process authorised payments but also have a duty to monitor accounts for fraud and intervene in unusual transactions, though payments pre-dating the CRM Code are not covered by that scheme.
Not upheldMonzo Bank Ltd
DRN-6039271A firm may decline reimbursement for fraud losses if the consumer lacked a reasonable basis for believing the investment was legitimate, but cannot refuse reimbursement based on inability to verify legitimate grounds if sufficient confidenc
Not upheldMonzo Bank Ltd
DRN-5952121Banks must balance fraud prevention obligations against execution of authorised payments; customers bear liability for authorised payments even if deceived, but banks may be liable if they fail to act on information that should alert a prud
Not upheldRevolut Ltd
DRN-5338575An EMI should monitor accounts for unusual transactions and intervene where suspicious activity suggests fraud risk, but customer non-cooperation with intervention attempts can prevent effective fraud detection.
Not upheldLloyds Bank PLC
DRN-6063898A consumer must provide sufficient evidence to prove funds were lost to a scam before a financial institution can be required to reimburse them.
Not upheldRevolut Ltd
DRN-5948140A payment services provider is expected to process authorized payments, but may intervene if transactions appear suspicious; however, intervention must be proportionate and the customer remains presumed liable in the first instance.
Not upheldBarclays Bank UK PLC
DRN-5948704A bank must process authorized payments but may intervene proportionately if it identifies fraud risk, though the consumer remains presumed liable in the first instance.
Not upheldLloyds Bank PLC
DRN-6236447A bank may be required to intervene on payments to protect customers from fraud where the transaction pattern raises concerns, but only if intervention would likely have prevented the loss.
Not upheldWise Payments Limited
DRN-6189235A firm must monitor for unusual transactions and intervene where there is elevated fraud risk, but intervention is only required if it would likely have prevented the loss.
Not upheldRevolut Ltd
DRN-6059715An EMI must monitor accounts for fraud risks and provide proportionate warnings when suspicious transactions are identified, but is not liable if clear warnings are given and the customer proceeds regardless.
Not upheldTriodos Bank UK Limited
DRN-6230627Banks must intervene on high-value cryptocurrency transfers to warn of fraud risk, but are not liable if the consumer ignores warnings and provides false information about the transaction purpose.
Not upheldRevolut Ltd
DRN-6189228A firm must monitor for unusual account activity and intervene to protect customers from fraud, but is not liable for losses where the customer resists protective questioning.
Not upheldMonzo Bank Limited
DRN-6189242A firm must monitor for unusual account activity and take reasonable steps to protect customers, but is not liable for losses unless its failure to intervene was the effective cause of the customer's loss.
Not upheldNationwide Building Society
DRN-6262928Consumers are generally liable for authorised payments, but banks must maintain adequate systems to detect and prevent foreseeable scams and provide tailored warnings, while consumers bear shared responsibility for losses where they fail to
Not upheldBarclays Bank UK PLC
DRN-6173225A firm is required to process authorized payments, but can only be held liable for APP scam losses where the consumer establishes fraud on the balance of probabilities, which requires evidence beyond mere hypothesis that the investment fail
Not upheldLloyds Bank PLC
DRN-6232664A bank's duty to protect customers from scams applies to the account holder entity, but reimbursement cannot be ordered unless that entity suffered the financial loss.
Not upheldLloyds Bank PLC
DRN-6225381A bank is not automatically liable for scam losses simply because a scam occurred; it must have reasonably prevented the payments or hindered recovery for recompense to be fair.
Not upheldLloyds Bank PLC
DRN-6161036A bank must process authorised payments, but should intervene proportionately where fraud risk is apparent, and liability depends on whether intervention would have prevented the loss.
Not upheldRevolut Ltd
DRN-5963918A payment services provider is expected to process authorised payments but should intervene if there are clear indications of fraud risk, with intervention being proportionate to the circumstances.
Not upheldLloyds Bank PLC
DRN-6231699A financial institution is not required to reimburse scam losses where the consumer cannot provide sufficient evidence that a scam occurred as described, particularly when the consumer's testimony alone cannot be reliably established.
Not upheldMonzo Bank Ltd
DRN-5825879Authorised Push Payment scams are only covered by the Reimbursement Rules where there is criminal deception; civil disputes between consumers and payees, such as dissatisfaction with goods or services, fall outside this protection.
Not upheldRevolut Ltd
DRN-5857347A payment service provider is not liable for authorised payments made by a customer unless it failed to intervene where it had reasonable grounds to suspect fraud and such intervention would likely have prevented the loss.
Not upheldRevolut Ltd
DRN-5889207An EMI must process authorised payments but should monitor for fraud risks; however, where a customer provides misleading information and ignores warnings, the firm is not liable for losses from scams they authorised.
Not upheldSantander UK Plc
DRN-5739625A bank is not liable for an authorised payment made by a customer to a genuine merchant, even if the customer was deceived by a scammer, unless the bank unreasonably failed to prevent or recover the payment.
Not upheldHSBC UK Bank Plc
DRN-6236572A bank is presumed not liable for authorized payments unless it reasonably ought to have prevented them or unreasonably hindered recovery.
Not upheldBarclays Bank UK PLC
DRN-6170970A firm is only required to reimburse an APP scam victim if the consumer has provided evidence establishing fraud on the balance of probabilities; mere investment failure does not constitute a scam absent supporting evidence.
Not upheldBarclays Bank UK PLC
DRN-6170978A firm is not liable for authorized payments unless the customer was demonstrably the victim of an APP scam, which requires proof on the balance of probabilities that fraud occurred rather than mere contract failure.
Not upheldHSBC UK Bank Plc
DRN-6189253A firm must process authorised payments but may be liable if it fails to intervene on unusual account activity, though intervention must have been likely to prevent the loss.
Not upheldRevolut Ltd
DRN-6260502A firm's fraud prevention obligations are predicated on establishing that a scam actually occurred and the consumer was coerced into it, which requires consistent evidence and testimony from the complainant.
Not upheldBarclays Bank UK PLC
DRN-6260386A bank's obligation to protect against fraud and scams is predicated on the consumer having been actually scammed, which requires consistent evidence of coercion and the circumstances of how the scam occurred.
Not upheldHSBC UK Bank Plc
DRN-6261809A bank is expected to process authorized payments, but may take additional protective steps if payment instructions are unusual enough to trigger fraud concerns under Payment Services Regulations 2017 and industry good practice.
Not upheldWise Payments Limited
DRN-6203651A bank or EMI must protect customers against fraud and scams so far as reasonably possible, but the starting position is that liability for an authorised payment rests with the payer, even if duped into making it.
Not upheldRightcard Payment Services Limited
DRN-5970281A payment service provider is not automatically liable for losses from authorised payments made by a scam victim, even if it provided warnings, unless it failed to act fairly and reasonably in the specific circumstances.
Not upheldBarclays Bank UK PLC
DRN-6156321A bank must process authorised payments but may fairly reimburse customers who fall victim to fraud if intervention could have prevented the loss, though the CRM Code does not apply to international payments.
Not upheldNATIONAL WESTMINSTER BANK PUBLIC LIMITED COMPANY
DRN-6200890Under the Payment Services Regulations 2017, a consumer is liable for authorised payments unless they can demonstrate they were unauthorised or that the bank failed to intervene when it should have done so.
Not upheldHSBC UK Bank Plc
DRN-6216715A bank is not automatically liable for losses from scams merely because a scam occurred; it is only fair to require reimbursement if the bank reasonably ought to have prevented the payments or hindered recovery, while the customer remains p
Not upheldRevolut Ltd
DRN-6042918An electronic money institution is expected to process authorised payments, and is not liable for fraud losses unless a proportionate intervention would have prevented the payment.
Not upheldBarclays Bank UK Plc
DRN-6232959Payments made in private civil disputes between consumer and payee, rather than criminal APP scams, are not covered by faster payment reimbursement rules.
Not upheldSantander UK Plc
DRN-6117413Banks must monitor accounts for fraud risks and intervene with warnings, but customers who ignore such warnings and are not forthcoming about payment purposes cannot recover losses under the CRM Code.
Not upheldRevolut Ltd
DRN-6247484An electronic money institution must process authorised payments but may take additional protective steps where transactions present heightened fraud risk, though consumers remain presumed liable for authorised payments in the first instanc
Not upheldLloyds Bank PLC
DRN-6207933A bank is presumed liable only where it should have prevented payments through additional checks, and liability should be fairly apportioned between the bank's intervention failures and the customer's own protective measures.
Not upheldWise Payments limited
DRN-5710773A payment made with the account holder's credentials and OTPs is authorised under the Payment Services Regulations 2017, even if the account holder was deceived by a scammer using remote access software.
Not upheldRevolut Ltd
DRN-6171602Cryptocurrency withdrawal services fall outside FOS jurisdiction as they are not regulated financial activities under DISP 2.3, though fiat currency transfers and conversions may be reviewable.
Not upheldBarclays Bank UK PLC
DRN-6258620A bank is not liable to refund money sent by a customer to a payment recipient they themselves selected and authorized, even if the recipient account was ultimately controlled by scammers, where the customer had the technical capability to
Not upheldSantander UK Plc
DRN-6197702A scam reimbursement claim under the CRM Code requires evidence that the recipient intended to defraud from the outset, not merely that a civil dispute or breach of contract occurred.
Not upheldLloyds Bank PLC
DRN-6184821The CRM Code only applies to APP scams where a customer is deceived into transferring funds to a different person or for fraudulent purposes, not to civil disputes with legitimate businesses.
Not upheldBarclays Bank UK Plc
DRN-6057296Under the Contingent Reimbursement Model (CRM) Code, a bank must reimburse customers for authorised push payment scams only where funds were transferred for purposes the customer believed were legitimate but were in fact fraudulent, excludi
Not upheldBarclays Bank Uk PLC
DRN-6101736Private civil disputes between consumers and payees are not covered by APP scam reimbursement rules; an APP scam requires evidence of criminal deception where either the recipient or purpose of payment was misrepresented.
Not upheldHSBC UK Bank Plc
DRN-5992448A bank is not liable for authorised payments made by a scam victim unless the bank's failure to intervene proportionately would have prevented the loss but for that failure.
Not upheldHSBC UK Bank Plc
DRN-6047329A bank is not liable for authorised payments made by a customer who was deceived, unless the bank failed to take proportionate fraud prevention steps that would have prevented the loss.
Not upheldBarclays Bank UK PLC
DRN-6232539APP scams require evidence of criminal deception; private civil disputes between consumers and payees are not covered by reimbursement rules.
Not upheldSantander UK Plc
DRN-6054112Payments to legitimate suppliers who fail to deliver goods or services constitute civil disputes rather than Authorised Push Payment (APP) scams and fall outside the Reimbursement Rules.
Not upheldHSBC UK Bank Plc
DRN-6191250A bank's primary obligation is to process authorized payment instructions without delay, and it is not responsible for protecting customers from risky investment decisions unless there is clear evidence of fraud that proportionate intervent
Not upheldMetro Bank PLC
DRN-6225036A bank's primary obligation is to process authorized payments without delay, and it is not responsible for protecting customers from risky investments unless it can be shown that a proportionate intervention would have prevented the loss.
Not upheldThe Royal Bank of Scotland Public Limited Company
DRN-6250307An Authorised Push Payment scam under the CRM Code requires dishonest deception about the purpose of the payment at the time it was made, not merely subsequent failure to deliver on promises.
Not upheldStarling Bank Limited
DRN-6039315A private civil dispute between a consumer and payee does not constitute an Authorised Push Payment (APP) scam under the FPS Reimbursement Rules, and banks are not liable for losses arising from such disputes.
Not upheldLloyds Bank PLC
DRN-5957196A private civil dispute between a consumer and a service provider over non-delivery of work does not constitute an Authorised Push Payment (APP) scam under the FPS/CHAPS Reimbursement Rules, even if the consumer believes they have been defr
Not upheldWise Payments Limited
DRN-6236075Payment service providers must process authorised payments but should take proactive steps to identify and prevent potentially fraudulent transactions; however, intervention will only justify refunding if it would have prevented the loss.
Not upheldBarclays Bank UK PLC
DRN-6236068A bank is expected to process authorised payments, but should proactively intervene in unusual transactions that suggest fraud risk; however, it is only liable for losses if such intervention would have prevented the scam.
Not upheldCo-operative Bank Plc
DRN-6055364A firm must process authorised payments but must also monitor for unusual transactions and take reasonable steps to protect customers; however, the consumer must demonstrate on the balance of probabilities that they were victims of an APP s
Not upheldCo-operative Bank Plc
DRN-6002702A firm must process authorized payments but customers must demonstrate fraud on the balance of probabilities to obtain reimbursement for investment losses.
Not upheldHSBC UK Bank Plc
DRN-6257717A customer who authorises a payment lacks a reasonable basis for belief that an investment is genuine when red flags such as social media sourcing, guaranteed returns, and personal account transfers are present, allowing the bank to rely on
Not upheldSantander UK Plc
DRN-6158829A bank's duty to prevent fraud is limited to what it could reasonably have identified based on observable warning signs, and the bank's obligation is assessed against whether it acted fairly and reasonably in its circumstances.
Not upheldRevolut Ltd
DRN-5911033A firm must be alert to unusual activity that could indicate fraud risk and take reasonable steps to warn customers, but the level of intervention must be proportionate to the risk and the firm is not liable if the customer was acting under
Not upheldSantander UK Plc
DRN-6098344A consumer who applies for a loan with knowledge and consent and receives the funds remains liable for the debt even if those funds are subsequently lost to a scam.
Not upheldNational Westminster Bank Public Limited Company
DRN-6151453A bank is not liable for authorised payments made by a scam victim unless a proportionate intervention by the bank would have prevented the loss.
Not upheldNewDay Ltd
DRN-5992515A failed high-risk investment in CFDs/forex through an automated trading robot does not constitute fraud or scam where funds were transferred to a regulated FCA firm and the loss resulted from trading fluctuations and margin calls rather th
Not upheldMonzo Bank Ltd
DRN-5992591A bank's obligation to protect customers from financial harm from fraud and scams only applies where funds are lost to an actual fraud or scam, not to failed investments in legitimate regulated entities.
Not upheldRevolut Ltd
DRN-6140990A payment service provider is only liable for authorised payments if they failed to intervene where reasonably expected and such intervention would have prevented the loss (causation requirement).
Not upheldNationwide Building Society
DRN-6181446A bank is not liable for reimbursement of payments to legitimate suppliers where the dispute is a private civil matter regarding quality or completion of services, rather than an APP scam involving fraud or dishonesty.
Not upheldBank of Scotland plc
DRN-6166767A bank is not liable for authorised payments made by a customer to scammers unless the transactions had characteristics that should have prompted intervention to protect against financial harm.
Not upheldSantander UK Plc
DRN-6138555A bank is expected to process authorised payments unless the transaction presents heightened fraud risk requiring intervention under its duty of care.
Not upheldRevolut Ltd
DRN-5913907Payment service providers must monitor accounts for fraud risks and intervene where transactions are unusual, but consumers are generally liable for authorized payments they make.
Not upheldMonzo Bank Ltd
DRN-6189691A bank's failure to question suspicious payments does not automatically entitle a consumer to reimbursement if intervention would not have prevented the loss.
Not upheldRevolut Ltd
DRN-6151455Payment service providers must process authorized transactions but should take proportionate steps to prevent fraud; however, liability requires both failure to intervene and causation that the intervention would have prevented the loss.
Not upheldNationwide Building Society
DRN-6183083A bank is not liable for authorised payments made by a consumer who was deceived about the recipient's identity, even if the bank fails to implement optimal fraud warnings.
Not upheldMitsubishi HC Capital UK PLC
DRN-6098364A consumer remains liable for a loan taken out with their knowledge and genuine consent, even if the funds are subsequently lost to a scam, provided they had use of the funds and have received compensation elsewhere.
Not upheld