The UK has seen a significant increase in Authorised Push Payment (APP) scams. An APP scam is when someone is deceived into sending their money to an account outside of their control. Whilst the victim may have intended to send the money, they do so because they have been tricked into sending it to a fraudster posing as a genuine recipient.

From 7 October 2024, if an APP scam takes place, banks and other payment services providers (subject to Reimbursement Rules), are required to reimburse customers who fall victim to APP scams. This is known as the Reimbursement Requirement.

The FPS Reimbursement Requirement applies to APP scam payments made over the Faster Payments Scheme (“FPS”). When applying the FPS Reimbursement Requirement, banks and other payment services providers must also comply with the FPS Reimbursement Rules. Full details of the FPS Reimbursement Rules can be found on Pay.UK’s website: https://www.wearepay.uk/wp-content/uploads/2024/09/FPS-Reimbursement-Rules-Schedule-4-v2.5.pdf

Separately, the CHAPS Reimbursement Requirement applies to APP scam payments made using CHAPS. When applying the CHAPS Reimbursement Requirement, banks and other payment services providers must also comply with the CHAPS Reimbursement Rules. Full details of the CHAPS Reimbursement Rules can be found on the Bank of England’s website: https://www.bankofengland.co.uk/-/media/boe/files/payments/chaps/chaps-app-scam-rules.pdf.

From 7 October 2024, if you are a victim of a scam, you may make a Reimbursement Request.

What is an APP Scam?

There are various types of APP scams. Primarily, these can be categorised as either:

• Malicious Payee scams, for example, a fraudster tricking someone into purchasing goods which do not exist or are never received, or
• Malicious Redirection scams, for example, a fraudster impersonating trusted persons (e.g. bank staff or police) to persuade the victim to transfer funds out of their bank account and into one under their control

How Do We Support You?

We are committed to protecting our customers against fraud through the implementation and use of effective systems and controls which can reduce the risk of such scams. This includes use of the Confirmation of Payee service, an account name-checking service designed to help reduce misdirected payments.

However, these controls can never be 100% effective and we encourage you to be alert to the risk of such scams taking sensible protection steps. The Government’s Stop! Think Fraud website (www.stopthinkfraud.campaign.gov.uk) offers valuable resources which may help you protect yourself.

Steps You Can Take to Protect Yourself from APP Scams

Remember that even where the name of an account matches the details provided, it could still be a scam.

In addition to the steps, we take to support you, there are steps that you can take to help protect yourself from APP scams, including:

1. Keep your personal information, including your usernames, address, bank details, passwords, email addresses and phone numbers, safe
2. If someone calls you claiming to be a bank employee, verify who you are speaking to by hanging up and calling the bank directly, even if the caller seems to know information about you. If the caller claims to be calling from Habib Bank Zurich plc, call us directly at 08081642242. We will NEVER ask that you transfer money between accounts or to a third-party account
3. Be careful on social media, and don’t share personal information or send money unless you are sure that who you are speaking to is who they say they are
4. Always question posts, phone calls or emails offering you deals out of the blue. If an offer seems too good to be true, it probably is

The following organisations provide free-of-charge support and advice about fraud:

• Action Fraud: Get in touch online (actionfraud.police.uk) or by calling 0300 123 2040
• Take Five to Stop Fraud (takefive-stopfraud.org.uk)

What Should You Do If You Think You Have Fallen Victim to an APP Scam?

At any point you consider yourself to be on the telephone with a fraudster, you should end the call immediately.

If you learn or suspect that you have fallen victim to an APP scam, it is important that you report the scam to us immediately. You can do so by calling 08081642242 or email us at appreimbursement.uk@habibbank.com. Please note that our lines are open from Monday to Friday 9 AM to 5 PM (excluding weekends and public holidays in the UK).

Making A Reimbursement Request

You can report details of an APP scam and make a request for reimbursement by submitting an APP Fraud Reimbursement Request Form (a Reimbursement Request).

You can access the Authorised Push Payment (APP) Scam Reimbursement Claim Form. Alternatively, you can complete an APP Fraud Reimbursement Request Form in any of our UK branches, or over the phone by calling 08081642242. A Reimbursement Request must be made within 13 months of the last APP scam payment made to the fraudster’s account.

If your request is validated, a reimbursable amount calculated in accordance with the FPS and/or CHAPS Reimbursement Rules (as applicable) will be provided to you within five business days of the Reimbursement Request being submitted, unless we have requested further information reasonably necessary to complete our assessment (the Reimbursement).

We may request further information from you, your agent, other payment services providers involved in the APP scam, law enforcement or other relevant parties.

If we are unable to complete our assessment of your Reimbursement Request within five business days, we will let you know and provide you with an updated estimated timescale where reasonably possible.

Every Reimbursement Request will be assessed on a case-by-case basis. To complete our assessment we may share relevant information, such as your name, account details and amount(s) of all the APP scam payment(s) reported by you with other payment services providers involved in the APP scam.

If you are not satisfied with the outcome of our assessment, you can raise a complaint in line with our Complaints Handling Process.

To Whom Do the FPS and CHAPS Reimbursement Requirements Apply?

The FPS and CHAPS Reimbursement Requirements apply to individuals, microenterprises and charities holding a relevant account, who are victims of an eligible APP scam payment made using CHAPS or FPS (as applicable) in the UK where the money is sent to a relevant account in the UK which is not controlled by them.

A microenterprise is an enterprise that employs fewer than ten persons and that has either an annual turnover or annual balance sheet total that does not exceed EUR 2 million.

A charity is a body whose annual income is less than £1 million per year and is a charity as defined by the Charities Act 2011, Charities and Trustee Investment (Scotland) Act 2005 or the Charities Act (Northern Ireland) 2008.

A relevant account for these purposes means an account which is held in the UK and provided to a service user (i.e. an eligible customer), and which can send or receive payments using either CHAPS or FPS. Please note, accounts provided by credit unions, municipal banks, national savings banks and (in relation to the CHAPS Reimbursement Requirement) Financial Market Infrastructure (FMIs) are not relevant accounts.

When Do The FPS and CHAPS Reimbursement Requirements Apply?

The FPS and CHAPS Reimbursement Requirements apply only to payments made on or after 7 October 2024.

Is There a Maximum Reimbursement Level and/or Excess?

The maximum level of reimbursement is £85,000, and the aggregated limit is applied across all payments which are authorised as part of the same APP scam.

An excess of £100 will be applied to any Reimbursement unless you were vulnerable at the time you made at least one of the APP scam payment(s) and this affected your ability to protect yourself from the APP scam.

Our assessment of vulnerability will also consider the financial impact of the excess on those with low financial resilience.

Are There Any exclusions?

There are a number of circumstances where a Reimbursement Request may fall outside the FPS and CHAPS Reimbursement Requirements, for example, where:

• the request for reimbursement is itself determined to be fraudulent, for example, because you are a party to the fraud
• the Standard of Caution exception applies (see Standard of Caution below)
• the Reimbursement Request is made more than 13 months after the date of the final APP scam payment made to the fraudster’s account, or before 7 October 2024
• the Reimbursement Request relates to an international payment
• the APP Scam Payment(s) took place across payment systems other than CHAPS or FPS, were made using cheque(s), cash, credit or debit card(s), prepaid card(s) and/ or have been made to an account which you control
• the payments were not authorised by you (for example, payments made as a result of a fraudster gaining access to your account and making fraudulent payments themselves directly)
• the payments are the subject of a civil dispute (for example, where payments have been made to a legitimate supplier(s) but goods or services received are defective in some way)
• the APP scam payment(s) are received into an account held with a credit union, municipal bank, national savings bank or (in relation to the CHAPS Reimbursement Requirement) a Financial Market Infrastructure (FMI)

Standard Of Caution

We are not required to provide a reimbursement where the Standard of Caution exception applies.

The Standard of Caution exception applies where, as a result of gross negligence, you have not complied with one or more of the following standards, except where you were vulnerable at the time you made at least one of the APP scam payment(s) and this affected your ability to protect yourself from the APP scam:

• You should have regard to any intervention made by us and/or by a Competent National Authority, for example, the police or National Crime Agency
• You should make a reimbursement request promptly upon learning or suspecting that you have fallen victim to an APP scam
• You should respond to any reasonable and proportionate requests for information made by us to support our assessment of your request, and
• You should, after making a Reimbursement Request, directly report the details of the APP scam to a Competent National Authority, for example, the police or National Crime Agency, or consent to us making a report to the police on your behalf

Complaints Handling Process

You can complain however you feel comfortable: Face to face, by phone, by letter, by e-mail or by speaking to any contact at Habib Bank Zurich plc. However, in order to give you the best service, we would prefer to receive complaints by email at contactuk@habibbank.com.

We hope you will be happy with what we propose. If you are not, you might be able to take your complaint to the Financial Ombudsman Service. Full details of our complaints handling process can be found here.

Changes To Our Terms & Conditions

By 9 April 2025, we will update the terms and conditions of our framework contracts with customers holding relevant accounts to ensure that we reimburse them as required by the FPS and/or CHAPS Reimbursement Requirements.