Resources

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Shifting Scam Liability : Payment Services Directive 3 (PSD3) Obligations for the EU

PSD3 and the EU Payment Services Regulation are moving scam liability off consumers and onto the institutions that process, facilitate, and profit from the infrastructure scammers exploit. The UK went first, and the October 2024 APP reimbursement regime made clear that reimbursement is just the visible part; the harder operational shift is what institutions need to prove they knew before the money moved. PSD3 takes that logic further. Pre-payment monitoring, receiving-side accountability, and cross-institution intelligence sharing are all on the table. The problem is that most bank fraud controls still trigger at the payment event, and by then the scammer has already coached the victim through every friction point. The scam journey starts days or weeks earlier, across telco networks, social platforms, and encrypted messaging apps, long before a payment instruction arrives. This report breaks down what PSD3 requires, what the UK's experience reveals about the operational shifts ahead, and why institutions that wait for final compliance deadlines will be building their fraud stack under pressure.

Report

The Scam Prevention Framework Sector Codes

The SPF draft codes change the question regulated entities have to answer. It is no longer only whether you stopped a scam. It is whether you can prove it. This briefing reads the primary Treasury instruments and sets out what equal shared liability, the signed statement of compliance and sector-specific control points mean for fraud, risk and trust and safety leaders across banking, telco and digital platforms.

Report

Inside the UK's Mule Account Economy

This report examines the role of mule accounts - the hidden infrastructure that enables stolen funds to flow through the UK's financial system. Drawing on real cases and industry insights, it highlights how these accounts fuel scams, sustain organised crime, and erode trust in banking and communications networks.

Report

Mule Accounts in Australia: The Hidden Infrastructure of Fraud

When Australians lose money to scams, the impact rarely stops with the first victim. Once stolen, the funds do not sit still. They move quickly, routed through layers of accounts that exist to disguise their origin. These accounts, known as mule accounts, are the silent infrastructure of modern fraud.

Guide

Preparing for SPF Enforcement (Telcos Edition)

This document outlines how Apate supports telcos and carriers in meeting incoming Scam Prevention Framework obligations. It maps Apate capabilities to each SPF principle, with a focus on evidence, operational outcomes, and defensibility under regulatory scrutiny and customer response expectations. The Framework was legislated in 2025, with sector codes and implementation guidance released by Treasury in November 2025. These materials clarify expectations around governance, investigation, actionable scam intelligence, disruption, reporting, and dispute resolution.

Guide

Preparing for SPF Enforcement (Banking Edition)

The Scam Prevention Framework is coming into effect in 2026, which will materially raise the bar for how banks must evidence scam prevention and response. Based on the legislation and Treasury consultancy, banks are expected to move beyond reactive, post-loss responses. They will need to demonstrate not only what actions were taken, but why those actions were reasonable given the information available at the time.

Report

The Illusion of Blocking: Why Blocking Calls Isn’t Stopping Scams

Telcos are blocking record scam volumes – but losses keep rising. Blocking works, and it has built customer confidence and regulatory trust. However, financial losses continue to rise as scammers adapt and find new ways to bypass defences. Blocking remains a critical first layer, but over-reliance introduces risks including false positives and degraded trust. This report explores why blocking alone is insufficient and highlights the need for real-time intelligence to strengthen detection, response, and disruption.

Report

Health Data for Sale: Inside the GP Medicare Data Harvesting Scam

This report examines a surge in Medicare-related scams during the festive season, where one in three scam sessions involved health data fraud. Attackers impersonated local GP clinics and used partial Medicare details to build credibility, with 78% of PII requests focused on healthcare information. The activity suggests a coordinated effort to harvest and resell sensitive data through black market aggregators.

Report

A Guide to Staying Scam-Safe: The Most Common Scam Types This Festive Season

The festive season should be a time of celebration. But for thousands of Australians each year, it's when scammers strike hardest – stealing not just money, but trust, time, and peace of mind. Covering the November to January period, this report outlines the most common scam types, supported by real loss data, and observed criminal tactics.