FCA Dear CEO letter: APP fraud reimbursement

On 7th October the FCA released a Dear CEO letter outlining its expectations on Authorised Push Payments (APP) Fraud reimbursement. Whilst the detail within the letter is light for a gap analysis, where appropriate, we have supplemented the observations with examples and additional details using previously released FCA guidance. The below publications have been used within this gap analysis:

  • FCA: Anti-fraud controls and complaint handling in firms (with a focus on APP Fraud)

  • FCA: Proceeds of fraud - Detecting and preventing money mules

  • FCA: Policy statement Fighting authorised push payment scams: final decision December 2023

  • FCA: FG22/5 Final non-Handbook Guidance for firms on the Consumer Duty

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