Letter from the table: Do not leave cross‑border fraud outside the standard

To the Fair Play Council,

I oppose the working draft clause that would limit reimbursement to payments made through domestic payment systems. A business does not become less exposed to fraud because the person who stole its money arranged for it to cross a border. I ask the Council to replace that clause with wording that covers qualifying authorised business payments made domestically or internationally.

On 7 April 2026, I received an email that appeared to continue an ordinary business conversation. It said that payment details had changed. The timing and tone seemed plausible, and the message was part of an existing exchange. I checked the invoice against the email and made the transfer the next morning, 8 April: AED 18,750 from my UAE bank account to the new overseas account shown on the invoice.

Later that day, I reached the person I had dealt with before using contact details I already had, not the details in the email. They told me they had not changed the payment account. The email account or correspondence had been compromised. I had not meant to send money to a stranger. I had approved a payment to what I believed was the right recipient, based on false instructions inserted into a real business exchange.

I called my bank on 8 April and asked it to try to recall the transfer. I followed up in writing and supplied the invoice, the original correspondence, and the corrected payment details. I also reported the incident to Dubai Police through its eCrime reporting service. I did these things promptly because I understood that the receiving funds might be moved quickly. By 6 May, no

money had been returned to me. I have not treated the recall request as a promise of recovery.

This is why a domestic-only clause would fail people in my position. The deception happened in the business correspondence. The payment instruction was approved from here. The destination account was abroad. A rule that ends at the border would make the location of the receiving account more important than the fraud itself. It would also leave a small business carrying the loss even when it reports quickly, provides the records, and asks its bank to act.

I understand the concern behind drawing a narrow boundary. Banks need a workable standard. A reimbursement rule should not turn every commercial disagreement, mistaken payment, or failure to check an invoice into a fraud claim. But that is not a reason to exclude cross-border payments altogether. The Council can set evidence requirements and assess the circumstances of each claim without making geography an automatic bar.

I propose this alternative wording:

“A qualifying business fraud claim is not excluded solely because the payment was made to an account outside the payer’s country or through a cross-border payment route. The payment provider shall take prompt, documented steps to request recall or recovery and shall assess reimbursement under the same fraud standard applied to a comparable domestic payment. The claimant must provide reasonably available evidence of the deception and report it promptly after discovery.”

That wording would not guarantee recovery in every case. It would require the provider to act quickly, keep a record of what it did, and assess the fraud rather than stop at the border. It would also recognize that a small business cannot usually see what happens inside a receiving bank or recover funds by itself.

In my case, the immediate practical steps were clear: contact the bank, request a recall, preserve the correspondence, and report the fraud. I took them. What I could not do was reverse the transfer or compel the receiving side to return the money. A standard should not imply that prompt reporting is enough to solve the problem while leaving the whole loss with the business that was deceived.