Crown Dependency regulators publish high-level principles for a coordinated APP fraud framework.

The Jersey Financial Services Commission (JFSC), alongside regulators in Guernsey and the Isle of Man, has published a joint high-level statement setting out agreed principles for a practical pan-Crown Dependency approach to Authorised Push Payment (APP) fraud.

• Crown Dependencies APP Fraud Framework (PDF on JFSC website): https://www.jerseyfsc.org/media/miqps50f/cd-app-fraud-framework.pdf

The document focuses on retail-customer banking activity and sterling payments made via Faster Payments and CHAPS.

• It is explicitly an early-stage alignment on common direction, not a finished set of rules.
• Detailed work on definitions, scope, reimbursement mechanics and other calibration points is still required and will involve further testing with industry, government and the ombudsman.

What is APP fraud?

• APP fraud occurs when a customer is deceived or manipulated into authorising a payment to an account controlled by a fraudster.
• Classic examples include impersonation scams (someone pretending to be from your bank, the police, HMRC or a supplier), romance or investment scams, and urgent requests to move money to a "safe" account.
• This differs from unauthorised fraud, where a criminal accesses your account or card without your knowledge or permission.
• The regulators note that the precise boundary between APP fraud and other payment/fraud scenarios will need further development to ensure clarity and consistent treatment.

Key elements of the agreed high-level position

• Scope: Retail customers and sterling payments over Faster Payments and CHAPS. We'll test the firm and customer perimeter through engagement to keep the framework proportionate and workable while aiming for consistent customer outcomes.
• Prevention, education and controls: The foundation must be strong prevention, detection, systems and controls, customer warnings, education and support for vulnerable customers. Banks will need clear expectations on how to respond when customers report suspected fraud.
• Reimbursement: The framework will address reimbursement, but the detailed approach (eligible claims, any cap, customer responsibility, vulnerability, and circumstances where reimbursement may be reduced or refused) remains to be settled. Any model must deliver meaningful customer protection while staying proportionate, pragmatic and workable.
• Cross-bank cost sharing: The current working view is that a cross-Crown Dependency inter-bank cost-sharing model would be operationally complex and should not be the starting point.
• Gross negligence, customer responsibility and vulnerability: These issues require careful treatment. Vulnerability should be taken into account in individual cases and outcomes, with the overall approach remaining evidence-based, proportionate and workable.
• Ombudsman engagement: Close working with relevant ombudsperson services will be important to support clear, consistent complaint handling across jurisdictions.
• The immediate next steps are collective engagement with trade bodies and government colleagues to test workability and identify operational issues, followed by putting practical working arrangements in place between the three Crown Dependency regulators.

What this means for consumers in Jersey, Guernsey and the Isle of Man

• This is a positive signal of coordination between the three jurisdictions.
• It signals an intention to develop clearer, more consistent expectations around prevention and, eventually, how APP fraud cases and complaints are handled for retail customers using sterling Faster Payments and CHAPS.

However, be realistic:

• This document contains no new enforceable rules, no guaranteed reimbursement rights, and no timelines for implementation. It is a high-level statement of direction intended to support further discussion. Detailed policies on reimbursement scope, any caps, customer responsibility tests and exceptions are still to be developed and tested.
• Consumers should not assume that banks in the Crown Dependencies will automatically reimburse APP fraud losses in the same way as under the UK's mandatory regime (which has applied to in-scope UK payments since 7 October 2024, with a £85,000 limit per claim and 50:50 cost sharing between sending and receiving payment service providers, subject to exceptions).
• Many customers in the Crown Dependencies also hold UK bank accounts or make payments that may already fall under UK rules depending on the payment service provider involved. Always check directly with your own bank about its current policies.

Action plan: Practical steps to protect yourself from APP fraud

While regulators and banks develop frameworks, the single most effective protection is your own vigilance. Here is a clear, evidence-based action plan drawn from established UK consumer guidance (which remains highly relevant given the sterling payment focus):

1. Stop and verify independently — If you receive an unexpected call, text, email or message asking you to make a payment, change account details, or move money to a "safe" account, stop. Verify the request using a known, trusted contact number or website you look up yourself — never use details provided in the suspicious message.
2. Resist pressure and urgency — Scammers create panic ("your account will be closed", "police need you to act now", "a loved one is in trouble"). Legitimate organisations do not demand immediate bank transfers under pressure.
3. Never share security credentials — Your bank, the police or any genuine organisation will never ask for your full PIN, online banking password or one-time passcodes. If they do, it is a scam.
4. Double-check large or new payments — For significant sums or payments to new recipients, confirm account details directly with the intended payee via a separate, trusted channel.
5. Use your bank's tools and alerts — Enable transaction notifications, review warnings shown in your banking app before confirming payments, and consider additional safeguards (such as dual authorisation) for vulnerable family members.
6. Support vulnerable people — If you or someone you care for is elderly, isolated, or otherwise vulnerable, talk openly about these risks and consider practical steps like joint account oversight or restricted transaction limits.
7. Act immediately if something feels wrong — Contact your bank straight away if you suspect you have been tricked into making a payment. The sooner you report it, the better the chances of recovery. Also report to the police or the relevant fraud reporting service.
8. Review regularly — Check bank statements and alerts frequently for anything unexpected.

For detailed, practical guidance:

• Take Five to Stop Fraud (UK campaign with excellent APP-specific advice): https://www.takefive-stopfraud.org.uk/protect-yourself/app-guide/
• Payment Systems Regulator consumer information on APP fraud reimbursement protections: https://www.psr.org.uk/information-for-consumers/app-fraud-reimbursement-protections/

Sources  

• Primary source – Crown Dependencies APP Fraud Framework (PDF on JFSC website): https://www.jerseyfsc.org/media/miqps50f/cd-app-fraud-framework.pdf
• UK Payment Systems Regulator – APP fraud reimbursement protections for consumers: https://www.psr.org.uk/information-for-consumers/app-fraud-reimbursement-protections/
• Take Five Stop Fraud – APP fraud guide: https://www.takefive-stopfraud.org.uk/protect-yourself/app-guide/
• Guernsey Financial Services Commission scams page (for local context): https://www.gfsc.gg/scams

This development is a constructive step toward coordinated protection across the Crown Dependencies, but it remains early-stage work. The strongest defence for consumers right now is consistent, sceptical verification of every unexpected payment request. If your bank has specific APP fraud policies or alerts, contact them directly for the most relevant information for your accounts.