Alice Drain
I am an associate in Bird & Bird’s Finance & Financial Regulation team, specialising in financial services regulation.
I assist clients across the financial services sector with a variety of regulatory and compliance matters, including payment services and e-money, payment system issues, perimeter guidance and financial promotions.
I trained at Bird & Bird. Before joining Bird & Bird, I worked in a variety of in-house roles at listed companies, with a focus on ethics and compliance. I have particular experience in financial crime issues covering anti-bribery and corruption, whistleblowing, and investigations.
Practice Area
Panel
- Contributing Author
Qualified Year
- 2024
Qualifications
- LLB (2016)
- LPC (2017)
Education
- Lancaster University (2016)
- BPP University (2017)
1 Contributions by Alice Drain
PRACTICE NOTES
UK Authorised Push Payment (APP) Fraud Reimbursement Regime: FPS and CHAPS Rules, 50:50 Sharing, £85,000 Cap, Exceptions, Deadlines, and FCA/PSR/BoE Oversight
Introduction
On 7 October 2024, the Payment Systems Regulator (PSR) and the Bank of England unveiled a compulsory reimbursement regime for payment services providers (PSPs) when customers fall victim to Authorised Push Payment (APP) fraud. As the PSR describes it, APP fraud arises where a criminal deceives someone (often a consumer) into sending funds to an account they do not control. The principal scam types include:
‘malicious payee’—for example, a fraudster induces a person to pay for goods that do not exist or are never delivered;
‘malicious redirection’—for instance, a criminal impersonates a member of bank staff to persuade someone to move money from their bank account into the fraudster’s account.
In-scope payment firms
The APP fraud reimbursement duty applies to these categories of payment firms:
all payment firms participating in the Faster Payments Scheme (FPS) that provide relevant accounts; and
all payment firms participating in the Clearing House Automated Payment System (CHAPS) that provide relevant accounts.
These entities were expected to comply with the...
Financial Services
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