RC/FP/2026/T.19 — A Letter from the Table: A Transfer Is Not the Whole Story

To the Fair Play Council

I am writing from Kingston, and I am putting this in English from the Jamaican Creole I hear owners use when they talk plainly among themselves. The story below is mine. The concern behind it is shared: we want help when money is stolen, but we do not want a rule that treats every authorized transfer as if it had the same cause or the same chance of recovery.

On 3 June 2026, an invoice arrived in an email thread I had used before. The amount was J$186,400. The message said the payment details had changed. I had seen warnings about changed invoices, including the Fair Play Council’s “Call before you pay a changed invoice” letter. I tried the contact number I already had, not the number in the new message. I could not get through before the end of the day. On the morning of 4 June, with the invoice due, I made the transfer from my business account to the account shown on the revised invoice.

Later that morning, I reached the real supplier using the old contact details. They had not changed their bank information and had not sent the new instructions. The money had gone to someone else.

I called my bank as soon as I understood what had happened. I asked it to stop or recall the transfer and gave the time, amount, reference number and the account details. I sent the invoice thread and the confirmation. I also made a report to the Jamaica Constabulary Force and kept the report details. I followed up with my bank and asked what else it needed to trace the payment. I did not wait for a perfect explanation before reporting it; every hour seemed important.

I am not going to pretend that I know what happened inside the receiving account. I do not know whether the money was still there when the recall request arrived. I do not know which institution could have stopped it, or whether a faster request would have changed the result. I know what I did, and I know the payment left my account. That is not the same as knowing who should bear the entire loss.

Jamaica has its own banking and payment arrangements, with the Bank of Jamaica as the central bank and an oversight role in the payment system. That matters when a proposal is written for use across borders. The practical route for a small owner here is to contact our bank, make a police report, preserve the records and keep asking for an update. I could not point to a general Jamaica-wide automatic reimbursement rule that would make a case like mine straightforward. A standard written elsewhere should not assume that every country already has the same process, evidence rules or division of responsibility.

My stance is opposition to the proposed fix if it makes reimbursement the automatic answer whenever a business authorized a payment after being deceived. I do not oppose helping victims. I do not oppose banks checking payee names where that service can be made reliable, or banks acting quickly on a properly documented recall request. I oppose treating those good measures and a broad reimbursement duty as one indivisible package.

For a small business, a name check could have helped me pause before paying, if it had been available and gave a clear result. A fast recall process could help the receiving institution freeze funds before they move again. Those are concrete changes. But a reimbursement rule also changes who pays when the money cannot be recovered, and how banks assess whether a business took reasonable care. If the standard does not say how that works for a cross-border transfer, a local transfer, a mistaken payment, and a convincing impersonation, it risks turning a complicated investigation into a simple blame decision.

That could bring a second harm. Banks may respond to unclear liability by adding more checks, delays or restrictions to ordinary business payments. The owner waiting to pay staff, a supplier or a government charge may then carry the cost of a system designed to protect them. And if every institution points to another country’s rules when the transfer crosses a border, the promise of reimbursement may sound stronger than the remedy that is actually available.

I ask the Council to separate the parts of the fix. Set a clear expectation for urgent recall requests, provide a usable record of what was attempted and when, and encourage payee verification that tells the sender plainly when details do not match. Then consult on reimbursement with small businesses and payment institutions in different jurisdictions before making it a universal requirement. Give special attention to cross-border cases: who receives the report, who contacts the other institution, what evidence is enough to start action, and what happens when funds have already moved.