APP Fraud Reimbursement UK: AML Context for Firms
In brief: APP fraud reimbursement rules are payment-system protections, while AML files still need to explain the funds, parties, risk, and escalation decision.
Key points
- Reimbursement does not remove the need to understand the transaction.
- Payment reimbursement rules change, so firms should check the current PSR material rather than relying on memory.
- Professional firms should check current rules and record AML risk separately.
What is APP fraud reimbursement?
APP fraud reimbursement refers to payment-system protections for victims of authorised push payment fraud. The Payment Systems Regulator has published current APP scams material, including protections, data, and policy context for Faster Payments and CHAPS.
For professional firms, reimbursement is not the same as AML clearance. A reimbursed payment may still require the firm to understand what happened, who was involved, and whether client funds or matter funds create risk.
AML questions after reimbursement
- Was the client a victim, recipient, intermediary, or adviser?
- Do payment records match the client's explanation?
- Are any funds being moved through the firm's matter or client account?
- Is there a risk the firm is dealing with criminal property?
- Has the MLRO or nominated officer reviewed the concern?
Practical file note
Record reimbursement status as context, not the conclusion. The AML conclusion should explain the funds, evidence, risk rating, and escalation decision.
See the Payment Systems Regulator's APP scams page for current reimbursement and payment-system context.
This guide is general information for AML risk assessment, not legal advice or fraud-investigation guidance. Use it alongside the firm's AML procedures, the Fraud Act 2006, the NCA's money laundering and illicit finance material, and supervisor guidance.