Stopping fraud at every step

Abstract

This article examines how payment firms deploy anti-fraud controls across the payment journey, from onboarding through to post-transaction recovery. The legal framework governing it is evolving quickly across both the UK and Europe, creating a more complex landscape for firms and their advisors. Rather than treating controls in isolation, it considers how they operate in practice and how they interact with the relevant legal and regulatory frameworks. The analysis is structured across three stages: pre-transaction, in-transaction, and post-transaction. Across each, the focus is on the practical operation of key controls, including customer due diligence, transaction monitoring, Confirmation of Payee, and reimbursement mechanisms for authorized push payment fraud. Drawing on practical experience, the article highlights the points at which legal expectations and operational reality can diverge and where firms are required to make judgement calls under pressure. The aim is to equip legal and professional advisors with a clearer understanding of how fraud prevention measures function in practice and where the key risks and decision points arise.