
When routine becomes complicity: the Cum/Ex aiding-and-abetting standard, applied to PSPs/acquirers
When can routine payment processing become complicity in fraud? EFRI examines German case law and why fraud indicators must be assessed together.

When can routine payment processing become complicity in fraud? EFRI examines German case law and why fraud indicators must be assessed together.

EFRI Briefing · 21 October 2026 · Mastercard Stablecoin Security and Qivalis’s planned euro token. This briefing analyses market and regulatory developments; it makes no finding of liability against any institution named. When a fraud victim’s money leaves a European bank and reaches a scammer’s wallet, the institutions along the

The latest Bank of America and American Express AML penalties repeat the failures exposed at ING in 2018. EFRI calls for credible licence restrictions, personal accountability and compensation for victims.

Austria Builds a Stronger Payment-Blocking Regime — but Repeats Germany’s Blind Spot Government Bill 594 d.B., XXVIII. GP (amendments to the Glücksspielgesetz and the Telekommunikationsgesetz 2021); introduced in the Nationalrat on 5 August 2026. The new § 56e GSpG enters into force at the end of 31 December 2026. EFRI

US and EU Asset Recovery is Failing Fraud Victims Authorities routinely celebrate their successes in tracing, freezing and confiscating criminal assets. Yet the crucial final step — returning those assets to the victims — remains fragmented, discretionary and painfully slow. Current cryptocurrency forfeiture proceedings in the United States expose the

Payment Fraud: Britain’s Bank-Refund Rule Works The first independent evaluation of the UK’s mandatory payment fraud reimbursement scheme is in and it validates the case EFRI has made for years. Forcing banks to refund scam victims cut authorised push payment (APP) fraud on the covered rails by around a fifth,

AI Fraud: The Mills Review Exposes Financial Enablers The UK Financial Conduct Authority’s Mills Review on AI and the future of retail financial services should not be read merely as a technology report. For consumer protection organisations, it is a warning about the next stage of industrialised financial fraud. The

$68 Billion Lost to US Scams — Europe Lacks the Loss Estimate A landmark new study puts a hard number on a problem victims have long felt in their bank accounts and their mental health. According to the new study “United States of Scams: The Financial and Emotional Fallout”, published

Københavns Andelskasse and Payvision: Victims Left to Chase Empty Shells Danish authorities have secured another conviction in the Københavns Andelskasse money-laundering scandal. But the case exposes a larger European failure. The victims are not only facing AML breaches. They are facing an enforcement model that confirms wrongdoing after the operating

The uncomfortable question is no longer whether banks had AML policies. The question is whether their published claims of group-wide control were ever tested against operational reality. A new EU standard exposes an old credibility problem Large European banking groups have told investors, regulators and the public for years that