The Difficulties of Obtaining Romance Scam Reimbursement in the UK
- Ken Palla
- 5 hours ago
- 7 min read
Although there is so much good news from the UK in the past few years about reimbursement and controls for consumer scams—in fact the UK is considered ‘top of class’, there are concerning changes in reimbursement occurring in 2025 that we need to discuss. To learn what these changes are, I spoke with Anna Rowe, co-founder of LoveSaid.
Anna Rowe and LoveSaid
Anna Rowe has been a victim of a romance scam and is also the co-founder of LoveSaid. LoveSaid is a fraud centre and think tank, dedicated to combating romance fraud. Anna, along with co-partner Cecilie Fjellhoy, are advocates for romance scam victims. As a free support service from LoveSaid, Anna helps UK victims obtain scam reimbursement from banks, and when necessary, from the Financial Ombudsman Service (FOS).
UK Government.
The consumer scam reimbursement mandate came into effect in October 2024, just after the Labour government came into control (more about this later).
Reimbursement Under the Previous Contingent Reimbursement Model (CRM)
Key Point: The CRM was in effect from 2019 until October 7, 2024. Under the CRM, reimbursement was limited to about 16 banks in the UK, primarily for faster payment scam transactions.
While the CRM was in place, Anna said these banks were more flexible when cases were presented. Often times cases would include domestic bank faster payments transactions and/or debit card transactions for gift cards (debit cards are technically outside the CRM) and the banks would reimburse many transactions. The banks were more willing to look at transactions other than Faster Payments and CHAPS, especially “if the bank could actually see that they had been pretty negligent.”
One case involved multiple intra-bank payments (not technically part of the CRM) involving £320,000 and the bank provided a full reimbursement.
Reimbursement Under the New Payment Systems Regulator (PSR) Mandate Effective Since October 7 2024
Key Point: Under the new PSR mandate, consumer scam reimbursements are covered for only faster payment and CHAPS transactions. All financial institutions are part of the new mandate.
Anna mentioned that since October 2024, it is becoming much more difficult for her to help victims file for reimbursement with the financial institutions and the Financial Ombudsman Service (FOS). She provided several reasons:
The financial institutions have become more rigid in defining the scope of transactions that will be reimbursed.
The FOS has totally changed the paperwork requirements for filing a claim. They now require dozens of questions to be answered in writing. A sample of these questions can be found below.
The time to prepare a reimbursement package has gone from 12 hours in 2024 (when the bank and FOS reimbursement claim package were basically the same) to 24-36 hours (if FOS appeal is required) because of these dozens of new FOS questions.
If the romance scam case involves different transactions (e.g. faster payments, debit card transfer, etc.), the FOS will split the case to multiple investigators.
The number of complaints filed with the FOS have risen, causing a significant backlog in 2025. As a result, it is taking the FOS much more time to resolve cases. Anna said “I've had cases from the beginning of this year that are still being investigated by the Financial Ombudsman now.”
Sample FOS Questions to be Completed
What communication methods were used after the initial contact, e.g. phone calls, WhatsApp.
Provide copies of all the written communication you had with them, including messages before and after the payments. For messages on a service like WhatsApp, export a full conversation as a text file. If this isn't possible, screenshots are fine, but please combine them in order onto one file.
Provide details of the scam amount, the dates and the amounts of the payments.
Where did the fund you sent come from? For example, was it your own salary or was it a gift or alone from someone else? If any funds were a gift or a loan, what was the agreement for you to repay the money?
What impact did losing the money have on you?
If you haven't already provided one, please describe step by step how the scam unfolded.
How did the scam start?
How did it proceed?
What persuaded you the payment requests were legitimate?
Do you recall seeing or hearing a scam warning from the bank when making the transfer? If so, what did you think of it? And did you take any additional action before proceeding?
Anna describes the new FOS process as equivalent to the police Crown Prosecution Service (CPS) criminal process. If you follow police crime shows as I do, you know the police have to build a very detailed case to present to the CPS in order to get a person charged with a crime. Anna said this new FOS process is ”like the victim is guilty (no reimbursement), unless they can prove their ‘innocence’.” This new FOS process conveniently coincides with the new Labour government decision to revise how the FOS works and to make the FOS “more balanced” between the customer complaining and the financial institution (e.g. reduce FOS payouts). In the June 25 2025 Financial Times article, the FT said:
“The UK’s financial ombudsman will be overhauled to stop it acting like “a quasi-regulator”, the City minister said on Thursday, opening the door to the potential introduction of a new appeal process for companies to challenge its decisions.”
“The proposed move to curb the powers of the FOS is part of a wider ministerial push to boost economic growth by easing regulation.”
“Scrutiny of the FOS has intensified after its rulings in favour of UK consumers complaining about alleged mis-selling of car finance, which threatens to become one of the country’s biggest financial scandals, costing lenders as much as £44bn in redress.”
There is no better way to reduce FOS payouts than to make the filing process so onerous that no one can get through the process. In fact, Anna is now seeing banks appeal the FOS decisions and many times winning. Prior to 2025, there was a near 100% consumer uphold rate for FOS decisions.
Anna also mentioned that in her experience, since October 2024, banks are much more reluctant to address any ‘out of scope’ transactions such a debit card scam transactions.
Crossover Cases
Anna also mentioned she has a number romance scams cases that have some transaction prior to October 7 2024 and some transactions after that date. These are more difficult to process. It is also amazing the number of these cases that have dozens of scam transactions that did not catch the attention of banks. Here is just one example that started in January 2024 and was never detected by the bank:
1 transaction (January)- debit card used to purchase gift card
4 transactions (late January)- debit card used four times in one day to buy £250 gift card each time.
1 transaction-£100 faster payment to another bank.
6 transactions (May 13-29)- debit card used to purchase gift cards
Multiple transactions- debit card used to send money to Western Union
Multiple transactions-More bank transfers faster payments
Multiple transactions- debit card used to send money to Western Union
9 transactions (same day)- debit card used to send money to Western Union
6 transactions- debit card used to purchase gift cards
And even more transactions…..
An example like this came up in the recent Financial Conduct Authority report on romance scam control weaknesses.
Summary
If romance scams cases are not quickly resolved by the financial institutions, it has become much more complicated and time consuming to appeal these cases with the FOS. And as the FOS is so backlogged and become like the “CPS criminal process”, it could dry up as an effective method to appeal any consumer scam losses.
With all this said, Anna agrees that the UK still has the best consumer scam reimbursement program in the world. In fact, the Payment Systems Regulator (PSR) has said that 88% of in scope claims are reimbursed and 97% of the time the reimbursement is made within 35 days. No other country comes close to that record. The PSR also reported that the percent of ‘out of scope’ claims have increased to 30%. Fraudsters are starting to move victims away from ‘in scope’ faster payments to other ‘out of scope’ transactions such as debit cards, crypto, cash withdrawals and international payments.
Anna deals with the claims that are either in scope and denied by the FIs or the 30% of the claims that may be out of scope. The process to support these victims has become more difficult since the PSR mandate came into effect last year. She also sees that the FOS is changing and making it a more difficult appeal process. She sees the FOS as “very much heavily weighted giving power back to the banks”. She did not expect that in 2025.
Anna will move forward and help victims such as “when you've got a 70-year-old that's been coached to send money to a crypto platform and the bank is not questioning why would a 70-year-old do this.” There is still much work to be done in the UK to help prevent consumer scams and LoveSaid will be part of the solution.
About Ken Palla
Since 2005, Ken Palla has been in Online Security. He was a Director at MUFG Union Bank, retiring in early 2019. At MUFG Union Bank he managed the online security for both commercial and retail customers. Ken was an advisor to the RSA eFraud Global Forum and a Program Committee member for the annual San Francisco RSA Conference.
In 2019, he received the Legends of Fraud Award. He has published many white papers—on the need to focus on online customer safety, on online authentication and on how to select a multi-factor authentication solution.
Most recently, he has been writing about consumer financial scams and how around the world financial institutions are adding scam controls and sometimes providing reimbursement. He is currently consulting to banks and to online security vendors and is a member of The Knoble Scam Committee.
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