As AMLA takes on its new EU-level role and the Single Rulebook continues to develop, where do you see the biggest areas of uncertainty for firms preparing for the new framework?
The biggest uncertainty is not whether scrutiny will increase – it clearly will – but how consistently firms will be able to operationalise the new framework across different products, markets and customer segments.
The Single Rulebook should bring greater harmonisation, which is positive, but firms will still need to interpret how expectations apply in practice: what data is required, how controls should be evidenced, how quickly alerts need to be investigated, and how local supervisors will apply the common framework.
From a Bottomline perspective, the practical challenge is turning regulatory change into repeatable, auditable controls. For Bottomline Financial Messaging customers, that means ensuring payments data is complete, screening and monitoring are embedded into payment workflows, and firms have the flexibility to adapt as regulatory expectations evolve. The firms that manage this best will be those that treat compliance not as a one-off regulatory project, but as part of resilient payment infrastructure.
How are PSR reimbursement requirements affecting the balance between customer protection, fraud prevention and recovery, particularly where scams and funds move across borders?
The PSR reimbursement model has changed the conversation. It has moved the industry away from thinking only about liability after the event, and towards preventing fraud before money leaves the account. That is a positive development for consumers, but it also creates real operational complexity.
Authorised push payment fraud is difficult because the payment instruction is legitimate on the surface, while the intent behind it has been manipulated. Once funds move rapidly across accounts or borders, recovery becomes much harder. So the balance needs to shift further towards prevention: better confirmation of payee, stronger behavioural and transaction monitoring, richer payment data, and faster intelligence-sharing across the ecosystem. Reimbursement is important, but it should not become the primary control. For Bottomline, this reinforces the importance of trusted payment connectivity, high-quality data, sanctions and fraud controls, and orchestration across the payment lifecycle. The goal should be to protect customers without introducing unnecessary friction into legitimate payments.
For multinational firms, what are the biggest practical challenges in aligning local fraud and KYC controls with different regional regulatory expectations?
The hardest challenge is achieving consistency without assuming every market is the same.
Multinational firms need a common view of risk, common standards for governance, and consistent evidence that controls are working. But at the same time, KYC, sanctions screening, fraud monitoring and reporting requirements vary significantly by jurisdiction, payment scheme and regulator. That creates a practical tension. If every country or business line implements controls differently, the firm ends up with fragmentation, duplication and inconsistent customer experiences. But if controls are too centralised or rigid, they may not meet local regulatory expectations.
The answer is a shared operating model with local configurability. Firms need consistent data standards, workflow, auditability and oversight, while still allowing controls to be tuned for local rules and risks. This is an area where our capabilities are highly relevant: helping firms standardise payment and compliance processes where they can, while retaining the flexibility to meet regional requirements.
Looking beyond regulation, what fraud trend do you think the industry is still underestimating?
I think the industry is still underestimating the speed at which fraudsters are industrialising social engineering. The technology is important – AI, deepfakes, synthetic identities and automation all matter – but the real risk is the combination of convincing digital journeys, real-time payments and psychological manipulation.
Fraudsters are becoming better at making victims believe they are acting in their own best interest, whether that is a consumer transferring money or a business approving a payment. That is particularly challenging in a world of instant and cross-border payments, where there is less time to detect and intervene. Traditional controls that operate after the payment has been initiated are no longer enough.
The industry needs faster, more contextual and more connected controls. In Financial Messaging, we see this as a data and orchestration challenge as much as a compliance challenge: bringing together payment data, beneficiary validation, sanctions screening, fraud indicators and workflow controls so firms can make better and more timely decisions.
What session are you most looking forward to seeing at the Fraud FS Summit and why?
The topics I am most interested in are the ones that bring fraud, payments modernisation and regulation together. Too often these are discussed separately, when in practice financial institutions have to solve them at the same time. Real-time and instant payments are a good example. They create better customer experiences and support innovation, but they also compress the time available to detect fraud, investigate concerns and stop suspicious payments.
The most valuable discussions will be around practical collaboration: how banks, payment service providers, technology partners, regulators and schemes can share intelligence, improve data quality and build controls that work at payment speed. Our focus is on helping institutions modernise payment connectivity while strengthening resilience, compliance and control. Fraud prevention is no longer something that can sit beside payment infrastructure – it has to be embedded within it.
About Edward Ireland
Edward has more than 25 years of experience in payments and financial technology. His current role drives thought leadership and solution development across the whole financial messaging portfolio covering connectivity, messaging, orchestration and regulation. His areas of specialisation are ISO 20022, Swift Connectivity, Real-Time Payments, Cross-Border Payments, Regulation and Operational Resilience.
Pre-Event insights from Bottomline – Associate Partner of Fraud FS Summit
The Fraud FS Summit brings together senior fraud and financial crime professionals for a full day of presentations, panel discussions, interactive roundtables and networking; inclusive of 2 course lunch and drinks reception with canapés. Join the UK’s leading fraud conference in London, view the latest agenda for the Fraud FS Summit here.
