Letter from the table: Put a clock on the recall process

RC/FP/2026/T.29 · 6 September 2026 · Stance: amend

To the Fair Play Council,

I support the direction of FP-001. A small business that sends a payment after being deceived should not be left to work out, alone and after the fact, which bank might still be able to stop the money. But I ask the Council to amend the draft before it becomes a standard. It should say what each institution must do, and by when. “Quickly” is not a procedure.

On 11 August, I received an email in an ongoing thread about an invoice. I keep the books and arrange payments for a small business in Sylhet. The message appeared to continue a familiar conversation, but the bank details had changed. I did not check the change by calling a number I already knew. That was my mistake. On 12 August, at about 11:20 in the morning, I sent BDT 186,400 from our business bank account to the new account details.

The next morning, the person we expected to pay told me no money had arrived. I went back through the email thread and saw that the payment instructions had been altered. I called my bank, then went to the branch with the invoice, transfer record and the messages. I asked for a recall and gave the account details I had used. I also made a written complaint. I was trying to give the bank enough information to contact the receiving institution while the money might still be there.

I cannot tell from outside the banks what happened to the funds after they arrived. I do know that the first hours mattered, and that I had no clear way to see whether a recall request had been sent, received or acted on. I was asked for documents, then asked for some of them again. I kept copies and followed up, but each follow-up was another task competing with the work

of keeping the business running. By the time I understood that there was no simple status update to expect, the most useful window may already have passed.

I searched for a rule that would tell me what reimbursement I could count on. The UK Payment Systems Regulator’s APP reimbursement scheme does not govern a transfer from a Bangladeshi account. I do not know of a Bangladesh-wide rule that guarantees reimbursement to a small business in this situation. Bangladesh Bank is the country’s central bank, but I could not find a simple route that would make a receiving bank return funds immediately just because I had reported a fraud. I am not asking the Council to claim that every loss can be recovered. I am asking for a standard that makes prompt action and a reasoned decision possible.

What I ask the Council to amend

First, define a response clock. When a customer reports a suspected fraudulent transfer, the sending provider should acknowledge the report promptly—within 30 minutes during its stated service hours—and open a recall request without waiting for a complete investigation. It should tell the customer what evidence is still needed. The receiving provider should be contacted urgently, and the sending provider should give the customer a status update within one business day. If a provider cannot meet a deadline, it should say why and give the next update time. These are proposed service standards, not claims about current Bangladeshi requirements.

Second, make the payee check useful in practice. Where a provider can verify a payee name against an account, it should show a clear match, partial match or mismatch before payment. Where it cannot, it should say that plainly rather than imply that the details have been checked. For small businesses, the warning should be available in Bangla as well as English, and should advise customers to confirm changed payment instructions through a separate, previously trusted contact method. A warning is not a substitute for verification, but a vague warning is not much protection either.

Third, set out a fair reimbursement test. A business should be able to submit a short, standard evidence pack: the transfer record, the invoice or payment request, the original and changed instructions, and the time the fraud was reported. Providers should preserve relevant transaction and contact records, assess the claim within a stated period, and explain a refusal in writing. Reimbursement should be considered where the customer acted in good faith and a provider failed to follow the agreed verification, recall or handling standard. The standard should not promise automatic payment in every case; it should prevent an unanswered complaint from becoming the final decision.

Finally, the rules must cover cross-border transfers. A local provider cannot promise that a foreign institution will follow the same timetable, but it can be required to send a complete, time-stamped request through its available channels, escalate it, and report what it has done. The standard should ask providers to publish the contact route and the minimum information needed for that request. Small businesses should not have to discover the right route while watching a loss unfold.