It also remains to be seen whether the introduction of a cooling-off period will be enough to break the spell that the fraudster often has over their victim during a scam.

The US will likely wait and see what works best, with reimbursement decisions currently at the discretion of banks on a case-by-case basis. The sheer scale of the banking market in the US often means that regulatory action is slightly behind other parts of the world. 

Killing scams at their origin  

One thing that is consistent across regions however is the desire for other parts of the scam chain to take action. This includes social media platforms and telecommunications providers – channels in which scams very often originate. 

In fact, UK Finance data shows that 77 per cent of fraud in the first half of 2023 originated from online platforms alone. On this basis there is an urgent need for social media firms to ramp up their efforts to combat this risk and play a more critical role in consumer protection. 

At the moment, banks are shouldering a disproportionate burden in the fight against fraud, while there is an absence of action from social media firms further up the 'kill chain'. 

Legislation will help to nudge such platforms in the right direction, but there is a lot of work to be done before we see a truly joined-up approach to tackling fraud. 

The future requires putting the human factor at the centre of technological innovation and a unified front. The fight against fraud requires collaboration and banks cannot continue to fight the battle alone.

Disruption requires cohesion across the ecosystem – social media and telcos are gradually joining the fight. Co-ordinated takedowns and intelligent data exchange are just some of the exciting possibilities of these joined up efforts.

Only by considering all stages of the scam risk can we best protect consumers.

Dan Holmes is fraud prevention subject matter expert at Feedzai