The responsibility for tackling fraud has long fallen disproportionately on financial institutions, with banks frequently left to tackle fraud that began long before it reached their systems. But now, there is growing recognition that this must change. The question argues Dave Rossi, Managing Director at National Hunter, remains how?ย
Historically, there has been a significant disconnect between where fraud originates and where responsibility falls. Financial institutions have found themselves carrying the burden of detecting fraud and reimbursing victims. But fraud rarely begins at the application stage or point of payment. Its origins are, in fact, much more dispersed, ranging from scam adverts and social media contacts to compromised telecoms channels and stolen identities, to name a few.
However, this is beginning to change, with UK policymakers recognising the need for every organisation involved in the fraud journey to play its part. With fraud accounting for more than 40% of all reported crime, tackling this escalating problem will require greater collaboration across all organisations, sectors and industry bodies. After all, the more organisations actively contributing to intelligence and intervention, the harder it will be for criminals to slip through the gaps. But the question that remains is: how does shared responsibility move from policy to practice?
UKโs recent move toward greater shared responsibilityย
In March 2026, the UK Fraud Strategy 2026-29 was announced, highlighting how fragmentation has allowed fraud to proliferate: โPartners across the public and private sector have their own unique insights, but there is currently no clear, shared and real-time picture of the fraud threat, meaning collective disruption is delayed or less effectiveโ.
In response to this, the Strategy laid out a whole-system approach, driving mandatory collaboration between the public sector, technology companies and financial institutions to fight industrialised fraud, alongside a new Online Crime Centre to enhance real-time data sharing and accountability.
Within the same month, the Payments Association called for a shared responsibility regulatory framework after it was revealed that a significant majority of APP fraud originated on social media platforms. Since then, we have seen further announcements such as Ofcomโs proposals to make technology platforms take greater responsibility for scam advertising, alongside increased expectations on telecommunications providers. These examples all highlight one key trend: a push for greater shared responsibility.
With the financial sector having long argued that fraud prevention requires every organisation involved in a customer’s journey to play its part, policy is increasingly moving the UK in that direction. However, while regulation can help establish expectations and encourage sectors to take greater responsibility, it cannot, on its own, create the relationships, processes and mechanisms needed to turn fragmented information into actionable intelligence. That practical work now needs to follow.
Focusing on prevention in practiceย
The growing understanding that fraud operates across multiple channels, rather than within the boundaries of one institution, is encouraging. Historically, each business in a fraud journey has only ever seen one piece of the puzzle, with data fragmentation working in the criminalโs favour. After all, an application viewed in isolation often appears legitimate, as businesses donโt have visibility of the signals that preceded it. Likewise, a fraudulent payment may be considered an isolated incident rather than part of a broader pattern of fraud. The policies taking shape create the opportunity for the bigger picture to be revealed. But greater responsibility will only improve outcomes if it results in useful intelligence being shared and acted upon earlier.
Today, successful intelligence sharing is already happening among financial service organisations, public sector counter-fraud bodies and law enforcement to identify patterns and disrupt fraudulent activity. Through established data sharing models, some organisations are contributing data that can then be cross-checked against intelligence from other organisations, helping identify connections and anomalies that would be unlikely to be seen when siloed. These relationships demonstrate what is possible when organisations look beyond the information held in their own systems and actively share intelligence with others.
This same principle can be extended beyond financial services. A social media platform may hold information about the account or advert through which a scam began, for example. Within the fraud journey, a telecommunications provider may see suspicious communications or patterns of activity. This will then reach a financial institution when it encounters a fraudulent payment or application. A data sharing model like the ones already established could be applied across these sectors to allow the crime to be uncovered much quicker.
How shared responsibility and intelligence leads to action
While every organisation has a part to play, and useful data to uncover, it is important to emphasise that shared responsibility does not require every organisation to solve the entire fraud journey. The most important thing for each organisation to own is its data. Organisations must understand which signals it holds, how those signals can help others and how they can be shared through appropriate channels before the criminal activity progresses further.
The firm must consider what data will be meaningful, and what will just result in more volume. Each organisation should therefore be asking two questions: what can we do about the fraud we see, and what intelligence do we hold that could help another organisation stop the next stage of it? Once determined, relevant intelligence must be collected and shared responsibly, through appropriate frameworks. This will enable organisations to quickly interpret data and act at the point where it can then make a difference before the fraud can progress further.
Conclusion
The direction of travel across policy and industry is encouraging. It has become increasingly accepted that fraud prevention cannot fall disproportionately on the organisation at the end of the chain. This greater recognition of shared responsibility and upstream prevention has begun to address some of those blind spots. The next challenge is turning that principle into meaningful, practical and most importantly, consistent, collaboration. Technology platforms, telecommunications providers, financial institutions, public bodies and law enforcement each hold different pieces of the fraud picture. The sooner relevant intelligence is shared responsibly and acted on, the greater the opportunity to stop fraud before it reaches the point of financial loss.
The aim of this should be to shift more intervention upstream, so that criminals are stopped before an account is opened, credit is granted or funds change hands. This in turn can reduce the need for reimbursement, protecting both victims and organisations from avoidable losses and reputational damage. It is all possible; what is needed now is sustained, practical collaboration to make shared responsibility a reality.
