A scam rarely begins when money leaves a bank account. 

It may start with an advert on a social platform, move into a private conversation, continue through a phone number or compromised device, reach a bank as an apparently authorised payment and pass through payment infrastructure before moving through mule accounts, crypto or overseas networks. 

At almost every stage, somebody can see something. 

The harder question is whether the organisation with the strongest signal is also the one able to act on it. 

The Signal and the Intervention May Sit in Different Places 

A platform may identify suspicious behaviour before a bank sees a payment. A sending bank may detect a material change in customer behaviour without knowing what triggered it. A receiving institution may see several victims paying the same beneficiary while each sending institution sees only one. 

This creates an operational gap between visibility and intervention. Beneficiary risk, mule indicators, previous scam reports and cross-channel behavioural signals become considerably more useful when they reach the function capable of acting before funds move again. 

For institutions, this shifts attention from simply collecting more fraud intelligence towards how quickly that intelligence can influence a decision. 

The question is not simply whether the signal exists, but whether it reaches the right intervention point in time. 

The UK Is Trying to Connect the Picture 

The Government’s Fraud Strategy 2026-2029 explicitly identifies fragmented data as part of the UK’s fraud challenge, with public and private organisations holding different insights without a clear, shared and real-time picture of the threat. 

Its response includes the new Online Crime Centre, led by the Home Office and NCA, bringing together policing, intelligence agencies and partners across financial services, telecommunications, technology and cyber to combine cross-sector data, identify threats and coordinate disruption. 

For financial institutions, the strategic implication extends beyond participation in another information-sharing initiative. External intelligence has to enter existing fraud operations in a form that can change customer or beneficiary risk, trigger intervention and establish clear ownership. 

Can cross-sector intelligence move through internal decision-making quickly enough to affect a live scam? 

Prevention Is Moving Upstream 

By the time a sending bank questions a payment, the victim may already have been manipulated. By the time a receiving institution identifies a mule account, funds may already be moving elsewhere. The transaction can therefore be one of the later signals in the scam journey. 

This puts greater emphasis on pre-transaction and beneficiary-side intelligence. The UK’s APP reimbursement regime reinforces that shift by splitting reimbursement costs between sending and receiving firms, creating incentives for both sides to strengthen prevention. 

Yet the PSR’s early assessment identified an important limitation: although communication between firms has improved, stakeholders reported that the information exchanged can still be limited. 

Reimbursement shares the cost after a scam. Prevention requires useful intelligence to move before or during it. 

Shared Responsibility Needs Clear Intervention Points 

No participant has complete visibility across the scam journey, making a single owner for the entire ecosystem unrealistic. A more practical operating-model question is whether ownership is clear at each intervention point. 

For financial institutions, that means knowing who acts when: 

• external intelligence identifies a potentially compromised customer or beneficiary; 

• multiple scam reports converge on the same receiving account; 

• behavioural signals suggest an authenticated customer is being manipulated; 

• a customer attempts another payment route after intervention; or 

• funds begin moving through a wider mule network. 

The objective is not necessarily to give one organisation ownership of the entire scam. It is to make sure ownership of the next intervention is clear wherever the risk appears. 
 
Who acts, on what intelligence and how quickly? 

Can the System Act on What It Already Knows? 

The UK’s emerging response points towards a more connected model of scam prevention. But connecting organisations and exchanging information does not automatically produce coordinated intervention. 

For fraud leaders, the operational test is whether intelligence can move from signal → decision → intervention quickly enough to interrupt the scam journey. That requires usable intelligence, defined ownership and escalation pathways capable of acting on information originating beyond the institution’s traditional perimeter. 

No single organisation may ever see the entire scam. The opportunity lies in making the partial views across the ecosystem actionable before the money, or the criminal network behind it, moves on. 

Who Gets the Chance to Stop the Scam First? 

On 22 October 2026, the 3rd Annual Fraud & Scams Leaders Summit UK will bring fraud leaders together in London to examine the questions now reshaping prevention, from intelligence sharing and customer journeys to identity, mule networks and the signals institutions may still be missing. 

As responsibility moves across banks, payments, technology, telecommunications and law enforcement, the question becomes increasingly difficult to avoid: 

Who could have stopped the scam first, and did they have the intelligence to do it? 

Join us for the conversations shaping what comes next. 

🎟️ Register using invite code: VIP-A to claim your complimentary delegate pass* 
 
When registering, please select “Delegate Registration” if you represent a financial institution. All consultants, solution and service providers must purchase a ticket. 

We look forward to seeing you in London!