Fraud, Laundering, and the Platforms in Between: What the Brussels Roundtable Signals for Every Compliance Program
The Facts
The roundtable, hosted with Regina Doherty MEP and moderated by AML Intelligence, brought more than 100 anti-fraud and financial crime leaders together to examine how criminals are using AI to industrialise scams. The backdrop is a fraud problem that keeps growing.
In the UK alone, authorised push payment (APP) fraud losses reached 576.4 million pounds in 2025, up 19 percent, across roughly 248,070 cases, according to the UK Finance 2026 Annual Fraud Report. Two-thirds of those cases, 66 percent, started online. Across Europe, one industry estimate puts APP fraud as high as 2.4 billion euros and rising 20 to 25 percent a year.
Three themes ran through the day, and each one carries a direct operational consequence.
Fraud and AML Are Converging
Fraud is the harm event. Money laundering is how the proceeds move, hide, and turn into spendable value. In APP fraud, investment scams, and romance scams, the deception and the laundering chain are stitched together. Investment fraud alone drove 221.5 million pounds in UK losses last year, up 40 percent.
If fraud sits only with the fraud team and laundering sits only with the AML team, the criminal owns the seam between them. Mule networks, layering, and victim funds cross that line constantly, and a siloed program sees two half-pictures instead of one.
- Connect your fraud and AML case data so a single analyst can follow funds from the scam to the cash-out.
- Share typology intelligence across both teams weekly, not quarterly.
- Test whether a confirmed APP fraud automatically triggers a laundering review on the receiving side. If it does not, that is your first fix.
Prevention Beats Reimbursement
Since 7 October 2024, UK payment firms must reimburse most APP scam victims up to 85,000 pounds, with the cost split evenly between the sending and receiving institution. It is a meaningful consumer protection. It is not a fraud reduction strategy. By the time a victim authorises the payment, the scam has already done its work through a fake advert, a cloned site, or a manipulated conversation.
Reimbursement moves money after the loss. It does nothing to shrink the volume of scams reaching your customers, and it puts a recurring cost on your balance sheet that you do not control.
- Shift investment toward the early signals: stronger payee verification and pre-transaction warnings tuned to scam patterns rather than generic alerts.
- Track your reimbursement outflow as a managed cost line, and report it to the board next to your prevention metrics so the trade-off is visible.
- Use confirmed cases to retrain detection rules, so each loss makes the next one less likely.
Responsibility Is Moving Upstream
Banks are no longer the only actors in scope. With 66 percent of APP fraud originating online, the roundtable pushed hard on the role of platforms, search providers, app stores, and telecoms. Taking down a scam advert after it is reported does little when criminals repost at industrial scale. The direction of travel is for platforms to verify advertisers and developers the way banks verify customers, and to face consequences when they ignore risks they could reasonably have seen.
For compliance officers, this is the start of a shared-liability ecosystem. Your institution will increasingly be expected to evidence not only its own controls but its coordination with the platforms and telecoms where fraud begins.
- Capture the origination channel of every reported scam, so you can show where fraud enters your customer base.
- Use that evidence in your information-sharing arrangements and, where the law allows, in recovery and liability discussions.
- Map which external intermediaries drive the most victim contact, and prioritise those relationships.
The Human Layer Still Matters
None of this removes the person at the center. Victims act under fear, urgency, and trust that has been deliberately engineered. Education and clear customer communication still reduce harm. The burden cannot fall on the customer alone, though, especially as scams grow more convincing and arrive through the channels people are told to trust.
Where This Goes
Europe is sketching a new fraud model: fraud and AML treated as one problem, prevention valued over reimbursement, and responsibility shared across banks, platforms, telecoms, and regulators. The US programs we work with are not bound by the UK rules, but the underlying logic travels. The institutions that connect their fraud and AML data, invest ahead of the payment, and document where scams originate will be ready for the questions an examiner has not asked yet. The ones that wait will be explaining the gap.