Crypto & Fintech · United Kingdom

APP Fraud Reimbursement and Crypto: Why the UK's Mandatory Refund Rule Often Doesn't Cover Crypto Investment Scams

Since October 2024, UK banks must reimburse most authorised push payment scam victims. But if you transferred to your own exchange account before the money reached a scammer, that specific step often falls outside the scheme entirely.

What the Mandatory Reimbursement Scheme Actually Covers

Since the Payment Systems Regulator's (PSR) mandatory reimbursement requirement took effect in October 2024, UK payment service providers must generally reimburse victims of authorised push payment (APP) fraud — where you were tricked into authorising a transfer to an account you believed belonged to a legitimate payee, but which was actually controlled by a fraudster. Reimbursement is split 50/50 between the sending and receiving institutions, up to a maximum of £85,000 per claim.

Reimbursement can be refused only in narrow circumstances: where you acted fraudulently yourself, or where you acted with "gross negligence" — a deliberately high bar, requiring the bank to prove you ignored a specific, clear warning, not merely that you were careless in a general sense. Vulnerable customers are exempt from the gross-negligence exception entirely.

The Structural Gap: Why Most Crypto Scams Fall Outside It

This is the detail that catches out most crypto scam victims, and it isn't a matter of bank discretion — it's how the scheme is legally defined. The scheme generally does not cover the full loss where your initial transfer went to another account that you yourself controlled — including your own account at a cryptocurrency exchange — with the funds only being moved on to the fraudster in a second step from there.

In the classic crypto investment scam pattern, that's exactly what happens: you transfer money from your bank to your own exchange account, then convert to crypto and send it onward to a fraudulent "investment platform" or wallet controlled by the scammer. The bank transfer itself, in this sequence, went to an account you controlled — the actual fraudulent step happened afterward, on the blockchain, outside the payment system the reimbursement scheme is built around. As a direct result, a significant share of crypto-investment fraud losses sit outside the scheme's protection, even though the victim experienced exactly the kind of manipulation the scheme was designed to address.

What You Can Still Do

What This Means for You

Don't assume the mandatory reimbursement scheme automatically applies just because you were scammed via a bank transfer — check specifically whether your money moved through an account you controlled (like your own exchange account) before reaching the fraudster, since that structural detail determines whether the PSR scheme technically applies. Either way, file a complaint with your bank, escalate to the Financial Ombudsman Service if unsatisfied, and report the fraud itself separately.

Generate a formal complaint routed correctly for your situation, and use our Crypto Scam Red Flags Checklist to help others avoid the same pattern.

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