DT Economics Managing Partner acts as PSR Settlement Decision Maker in Bank of Ireland UK fining

DT Economics Managing Partner David Thomas, acting as a Settlement Decision Maker for the Payment Systems Regulator, has issued a Decision Notice fining Bank of Ireland UK £3,779,300 for failing to implement Confirmation of Payee (CoP) by the required deadline.

CoP is an account name-checking service designed to protect customers from authorised push payment fraud - where criminals pose as legitimate organisations to trick people into transferring money - and from misdirected payments caused by clerical error. The PSR directed payment service providers to implement CoP under Specific Direction 17, published in October 2022, with the largest Group 1 institutions required to comply by 31 October 2023.

Bank of Ireland UK was the last Group 1 provider to achieve compliance. Its period of non-compliance ran from 31 October 2023 to 7 January 2025, during which approximately £6.9 billion of transactions were sent without the required CoP coverage, affecting payments to more than 1.14 million new payees. Customers setting up new payees during that period did not benefit from the account name-checking safeguards the direction was designed to provide.

Bank of Ireland UK agreed to settle early in the enforcement decision-making process, qualifying for a 30% reduction in the penalty. Without that discount, the fine would have been £5.4 million.

This is the third PSR enforcement action in which David Thomas has acted as Settlement Decision Maker, following fines issued to NatWest Group banks in 2022 and Barclays in 2022. Further details are available on the PSR's website.