This breakdown of the APP fraud liability shift is incredibly timely. The part about making fraud a P&L line item completely changes the incentive structure for financial insitutions, because right now there's basically no cost to being a conduit for stolen funds. If the CBN actually enforces this modeled on the UK PSR approach, you'll see overnight investment in fraud detection infrastructure that should have been built years ago. The only wildcard is whether "grossly negligent" becomes a loophole banks exploit to dodge reimbursement in edge cases.
I think I'll do that as a separate post. There's definitely enough activity from the CBN these last few months to suggest that 2026 will be interesting.
"see you on Wednesday"
One week later...
This breakdown of the APP fraud liability shift is incredibly timely. The part about making fraud a P&L line item completely changes the incentive structure for financial insitutions, because right now there's basically no cost to being a conduit for stolen funds. If the CBN actually enforces this modeled on the UK PSR approach, you'll see overnight investment in fraud detection infrastructure that should have been built years ago. The only wildcard is whether "grossly negligent" becomes a loophole banks exploit to dodge reimbursement in edge cases.
I'm also keen to see how the banks define "gross negligence," although I suspect that will not be left for the banks to decide.
2026 will definitely be an interesting year for regulation.
So what's your outlook for the CBN 2026 policies?
I think I'll do that as a separate post. There's definitely enough activity from the CBN these last few months to suggest that 2026 will be interesting.
I'll be waiting 🙌🙏🙏🫡