Pros and Cons of Anti-Scam Rules in UK, Australia, Singapore

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November 5, 2024    

Governments globally are intensifying anti-scam measures, introducing new guidelines to banks, telecom providers and other key sectors to bolster security controls and mitigate fraud risks for consumers and businesses.

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Though the overarching strategy remains the same – requiring higher accountability from institutions handling financial and personal data – each country’s approach has unique elements. While the U.K. and Singapore focus on imposing heavy penalties on banks, Australia has taken a unique stand to focus solely on improving controls and ensuring real-time monitoring through collaboration among various stakeholders.

In Singapore, the Monetary Authority of Singapore has established a waterfall approach, prioritizing FIs for compensation if they fail in their responsibilities, with telecoms also held accountable. The U.K. follows a similar compensation model, though it primarily targets financial institutions, providing limited involvement from other sectors.

Australia, in contrast, has a framework that does not mandate formal victim compensation. Instead, it emphasizes real-time intelligence sharing and scam disruption, including not only banks and telecoms but also internet service providers and social media companies. This approach seeks to prevent losses before they occur, making Australia’s anti-scam model a unique case study.

Where Are the Gaps?

These differing approaches across the three regions provide key insights into each government’s priorities and reveal areas where improvements could strengthen overall scam prevention efforts.

The U.K., a pioneer in tackling authorized push payment scams, has taken steps to reimburse victims. But the U.K. could benefit from expanding its reimbursement framework to cover additional stakeholders beyond banks, and to include other payment systems, such as the Clearing House Automated Payments System, or CHAPS. These changes could provide a more comprehensive safety net for consumers, extending protections beyond faster payments to cover a broader range of transactions.

Singapore’s shared responsibility framework assigns specific roles to banks and telecoms in cases of phishing scams with direct Singaporean connections. Yet, the framework has gaps, covering only phishing. Expanding this framework to address other social engineering scams and scams originating outside Singapore could enhance consumer protection and broaden the scope of its anti-scam measures.

In Australia, the absence of a compensation requirement has drawn criticism from some who argue it offers limited recourse for scam victims. Critics also contend that penalizing banks, telecoms and tech providers alone may not address the root causes of scams, especially given the frequency that scammers access personal contact information through the dark web or public websites.

Lessons for the Future

As scams become more sophisticated, each country could benefit from borrowing elements of other frameworks. The U.K. and Singapore might enhance consumer protection by broadening the scope of their reimbursement schemes to include more stakeholders and scam types. Australia’s proactive model, focused on real-time intelligence and prevention, could inspire other countries to prioritize stopping scams before they reach consumers.

But the question remains: Will countries strike the right balance between prevention and compensation, or will they continue to emphasize one approach over the other?

The success of these anti-scam frameworks will be measured by their adaptability in responding to emerging scam threats. Time will tell if these measures are enough to keep pace with increasingly sophisticated scams. Until then, let’s hope other countries introduce strong measures to reduce scams and protect consumers.