EU · LATAM

Fraud regulation, tracked

What is coming, when it bites, and what it obliges a fraud team to build — across the EU and Latin America. Every entry cites its sources and says how firmly it is verified.

24
Instruments tracked
4
Deadlines still ahead
6
Jurisdictions
7
Days to the next one

Last reviewed 16 Sep 2026

Brazil Adopted
7 days

DICT Manual v8.5 — query limits and fraud notification

Manual Operacional do DICT v8.5 ·DICT Manual v8.5 (secs. 10, 14) ·Banco Central do Brasil

Section 14 governs API query rate limits on the Pix key directory; section 10 governs Infraction Notification, the fraud-marking mechanism. Version 8.5 carries two effective dates.

  • 1 Sep 2026 v8.5 effective (first tranche)
  • 26 Oct 2026 v8.5 effective (second tranche)
What it obliges you to do

Budget DICT lookups per end user — key-validation and beneficiary-check features can exhaust a customer's token bucket — handle HTTP 429 gracefully, and treat abnormal 404 rates as an enumeration-attack signal. Reported buckets are 100 tokens for CPF and 1,000 for CNPJ, replenishing at 5 per minute, with 20 tokens charged on a 404; these figures come from a vendor summary, not the manual text.

Open question

Content of v8.5 was not retrievable; the token-bucket figures are from a vendor help page rather than section 14 itself. Verify against the manual before sizing capacity.

Unconfirmed checked 16 Sep 2026 scheme rules instant payments
Mexico In force High impact
18 days

Facial biometrics mandatory for identification — compliance due late 2026

Reforma a la CUB — Arts. 51 Bis a 51 Bis 5 y Anexo 71 ·DOF 01/07/2026, nota 5792307 ·CNBV

Adds facial biometrics alongside fingerprint. Enrolment is a 1:1 verification against INE, SRE or other federal authority records with a minimum 90% match threshold; subsequent transactions verify 1:1 against the institution's own biometric database.

  • 1 Jul 2026 Published in DOF
  • 2 Jul 2026 In force
  • 6 Nov 2026 Compliance — 90 business days from entry into force Approximate — count business days against the official calendar.
What it obliges you to do

Biometric verification is required for higher-risk in-person operations on Level 3 and Level 4 accounts. Biometric databases may not be shared, sold or transferred without CNBV authorisation; vendors may operate the systems but the institution retains data governance. Technical specifications sit in Anexo 71. Institutions already running biometric databases had 30 calendar days to notify CNBV, and must give 20 business days' notice to discontinue one.

Primary source checked 16 Sep 2026 biometrics onboarding kyc
Mexico In force
56 days

SPEI mobile transfer UX standardisation — constrains antifraud friction

Circular 9/2026 (modifica Circular 14/2017 — SPEI) ·Circular 9/2026 ·Banco de Mexico

Mandates conformity with Banxico guidance standardising the mobile transfer user experience: usability, communication and the handling of transfer requests.

  • 17 Jun 2026 Published
  • 18 Jun 2026 In force
  • 14 Dec 2026 Compliance deadline
What it obliges you to do

This is a UX harmonisation rule, not a fraud rule — but it constrains how fraud teams can design friction, warnings and confirmation screens in the mobile SPEI flow. Anti-scam interstitials should be checked against the Guias before the December deadline rather than after.

Primary source checked 16 Sep 2026 instant payments
EU In force
263 days

Verification of Payee deadline for non-euro-area PSPs

Instant Payments Regulation ·Regulation (EU) 2024/886, Art. 5c ·European Parliament & Council / EPC

PSPs in EU Member States outside the euro area have a later compliance date for the same VoP obligation.

  • 9 Jul 2027 Compliance deadline (non-euro area)
What it obliges you to do

Same requirements as the euro-area obligation. Relevant to any group operating across euro and non-euro EU markets, where a single VoP platform has to serve two different go-live dates.

Secondary source checked 16 Sep 2026 verification of payee instant payments
Chile In force
In effect

Open finance phasing — payment initiation as a new APP fraud surface

NCG n. 514 — Sistema de Finanzas Abiertas (Ley Fintec 21.521) ·NCG 514; NCG 559 ·CMF

Regulates the open finance system under the Fintech Law. Banks, insurers and fund administrators are mandatory information providers; payment-initiation and information-based service providers participate voluntarily. Section III covers system security and safeguards.

  • 3 Jul 2024 NCG 514 published
  • 3 Jul 2026 Initial phase — 24 months from publication
What it obliges you to do

Gate data sharing on explicit user consent, secure the provider and consumer interfaces per section III, and treat payment initiation as a new authorised-push-payment fraud surface subject to the Ley 20.009 restitution clock. Phasing runs roughly five years: 24 months from publication for the initial phase, then 18 months for banks and card issuers, then a further 18 for cooperatives, insurers and fund administrators.

Secondary source checked 16 Sep 2026 open finance data sharing
Mexico In force High impact
In effect

Monto Transaccional del Usuario — per-customer transaction limits

160a Resolucion modificatoria a la CUB ·DOF 14/06/2024, nota 5730493 — Arts. 287 Bis, 287 Bis 1, 316 Bis 13, 164 Bis 1 ·CNBV

Creates a per-user transaction limit set by the customer at onboarding or in digital banking. If the customer does not set one, the institution must estimate it within six months. Changes require two distinct authentication factors, and transactions above the limit require additional authentication.

  • 14 Jun 2024 Published in DOF
  • 1 Oct 2025 Codes of conduct — banca multiple
  • 2 Jan 2026 Implementation — banca de desarrollo
  • 2 Jul 2026 MTU determined for all users — banca de desarrollo
What it obliges you to do

Beyond the MTU itself: automated alerting on deviations from the user's typical pattern including consumption and geolocation (Art. 316 Bis 13); a formal board-level fraud prevention plan (Art. 164 Bis 1) with biennial effectiveness audit; and 48-hour refunds on monetary claims (Art. 310). This is why Mexican banks began step-up-authenticating or blocking above-limit transfers from January 2026.

Primary source checked 16 Sep 2026 transaction monitoring reimbursement liability
Colombia In force High impact
In effect

Identity theft law reverses the burden of proof onto the institution

Ley Estatutaria 2573 de 2026 ·Ley 2573/2026; Sentencia C-413/25 ·Congreso de la Republica / Corte Constitucional

On notification of suspected identity fraud the institution must immediately suspend all collection — including interest and collection costs — and hand the victim copies of every document used to approve the credit. On confirmation, the negative credit report is deleted and the record re-tagged as 'Victima de Falsedad Personal', which may not prejudice future credit assessment.

  • Dec 2025 Constitutionality confirmed (C-413/25)
  • 19 May 2026 Effective
What it obliges you to do

The burden of proof is reversed under 'carga dinamica de la prueba': the institution must evidence the specific identity-verification mechanism it used. Fraud teams must therefore retain per-application verification artefacts — document checks, liveness, device, biometric match scores — for as long as a claim can be raised. Victims have 20 business days to file a Fiscalia report after notifying the institution.

Secondary source checked 16 Sep 2026 reimbursement onboarding kyc liability
EU Agreed High impact
In effect

Full reimbursement for PSP-impersonation (spoofing) fraud

PSR — Payment Services Regulation ·PSR Art. 59 (2023/0264(COD)) ·European Parliament & Council

Where a fraudster impersonates the consumer's own PSP — misusing its domain name or communication channels — and manipulates the consumer into authorising a transfer, the PSP must reimburse the full amount. Note the scope: this is impersonation of the customer's own bank, not general third-party-payee APP fraud.

  • 28 Jun 2023 Commission proposal
  • Nov 2025 Provisional political agreement
  • 22 Apr 2026 COREPER endorsed trilogue texts
  • 23 Apr 2026 Agreed final texts published (Council)
  • — Application — 21 months after OJ publication OJ publication not yet confirmed as of 2026-09-16.
What it obliges you to do

Build a reimbursement case workflow with two conditions on the consumer — report to police and notify the PSP without undue delay — and a refund clock. Reported refund deadline is 15 business days from notification plus police report. The burden of proof sits with the PSP to show consumer fraud or gross negligence in order to escape liability, so authentication, device and behavioural evidence must be retained per case, not just the transaction ledger.

Open question

Formal adoption and Official Journal publication were still unconfirmed at the latest source date (2026-05-29). Sources anticipated OJ publication June/July 2026 with possible slippage to September. Confirm against EUR-Lex before relying on any application date.

Secondary source checked 16 Sep 2026 reimbursement liability
Colombia In force
In effect

Open finance becomes mandatory, SEDPEs in scope

Decreto 0368 de 2026 + SFC CE 009/2025 y CE 001/2026 ·Decreto 0368 de 2026 (modifica Decreto 2555/2010) ·MinHacienda / URF / SFC

Makes open finance mandatory for credit establishments, SEDPEs, fiduciarias, insurers, comisionistas de bolsa and pension administrators. SFC Circulares Externas 009/2025 and 001/2026 set the transition regime for architecture, security and technology standards.

  • 6 Aug 2025 SFC CE 009/2025
  • 3 Feb 2026 SFC CE 001/2026
  • 7 Apr 2026 Decreto 0368 published
What it obliges you to do

Extend consent, authentication and anomaly detection to third-party data-access and payment-initiation channels under 'medidas de responsabilidad demostrada'. SEDPEs are explicitly in scope, so low-KYC e-money players carry the same API-security burden as banks. Phasing: SFC participant directory within 12 months; standards and implementation schedule within 6 months; data-sharing enablement 12 months after standards, extendable by 6.

Secondary source checked 16 Sep 2026 open finance data sharing
Colombia In force
In effect

Bre-B framework update and the rise of llave-based phishing

Bre-B — actualizacion del marco regulatorio ·Anuncio de 27/03/2026 — numero de resolucion no identificado ·Banco de la Republica

The central bank updated the Bre-B instant payments framework with clearer disclosure of the origin of technological failures and more precise user-notification protocols.

  • 27 Mar 2026 Framework update announced
What it obliges you to do

Operationally, Bre-B llaves have become a live phishing and smishing vector across Colombia through 2026. Fraud teams need beneficiary-key validation, SMS-impersonation monitoring and a key-based view of mule accounts — the same alias-reputation control surface that Pix and SPEI are converging on.

Open question

The underlying resolucion externa number and its effective dates were not published on the announcement page. Identify the instrument number before citing it.

Unconfirmed checked 16 Sep 2026 instant payments scheme rules
Brazil In force High impact
In effect

MED 2.0 — multi-hop tracing and blocking of Pix fraud proceeds

Resolucao BCB n. 493/2025 — MED 2.0 ·Res. BCB 493, de 28/08/2025 (altera Res. BCB 1/2020) ·Banco Central do Brasil

Upgrades the Special Return Mechanism so that stolen funds are traced beyond the first receiving account, with automatic preventive blocks across successive accounts in the chain.

  • 28 Aug 2025 Published and in force
  • 2 Feb 2026 Mandatory for all Pix participants
What it obliges you to do

Implement chain-tracing via DICT and GRAF with multi-layer blocks rather than first-hop only. Receiving PSPs have up to 7 days to accept or reject an Infraction Notification and up to 72 hours after analysis to request the refund. A self-service contestation button in the app has been mandatory since October 2025.

Open question

Article-level numbering and exact entry-into-force clauses should be confirmed against the BCB normativos portal; the BCB text was not directly retrievable.

Secondary source checked 16 Sep 2026 reimbursement scheme rules instant payments
LATAM In force High impact
In effect

Four markets converging on the same three design choices

Regional convergence — reimbursement regimes ·Cross-jurisdiction trend, not a binding instrument ·Multiple

There is no binding region-wide fraud instrument — GAFILAT's mandate is AML/CFT, not consumer payment fraud. But Brazil, Chile, Colombia and Costa Rica are independently converging on reversed burden of proof, statutory restitution clocks, and mandatory blocking of destination accounts.

  • Feb 2026 Costa Rica bill approved in committee
What it obliges you to do

A fraud team operating in more than one of these markets should build one reimbursement-case engine with per-country clocks and thresholds, rather than four separate ones. The second convergence is scheme-level fraud markers on destination identifiers — Pix infraction notifications, Bre-B llaves, SPEI — making alias reputation a shared regional control surface.

Secondary source checked 16 Sep 2026 reimbursement liability
Chile In force High impact
In effect

Fraud restitution: 35 UF threshold for 2026, burden of proof on the issuer

Ley 21.234, modificada por Ley 21.673 + DS Exento n. 473 ·Ley 21.234 (2020); Ley 21.673 (2024); DS Exento 473 (2026) ·Congreso / Ministerio de Hacienda

On the user's notice the issuer must block immediately. Users are exempt from liability for operations after notice and may dispute transactions up to 120 calendar days before it. Restitution is within 5 business days for claims up to the threshold; above it the issuer has 7 additional days to restitute or to sue alleging gross negligence or fraud.

  • 29 May 2020 Ley 21.234 published
  • 30 May 2024 Ley 21.673 amendment
  • 30 Jan 2026 DS Exento 473 — threshold held at 35 UF for 2026
What it obliges you to do

Operate a 5-business-day auto-restitution lane below the threshold and a separate evidence-backed lane above it, plus a documented suspension and self-fraud workflow able to survive juzgado de policia local review. The transaction log alone is expressly insufficient to prove authorisation or user fault, so device, behavioural and authentication evidence must be retained. Ley 21.673 moved the threshold out of the statute: Hacienda now sets it annually by decree within a 15-35 UF band, so re-check it every year.

Primary source checked 16 Sep 2026 reimbursement liability
Brazil In force
In effect

Real-time antifraud controls for SPI direct participants

Resolucao BCB n. 524/2025 ·Res. BCB 524, de 18/11/2025 ·Banco Central do Brasil

Direct participants in the instant payment system must monitor atypical movements in real time against historical and behavioural patterns, and be able to halt processing on suspected system compromise.

  • 18 Nov 2025 Published
  • 1 Dec 2025 In force
What it obliges you to do

Configure PI-account minimum-balance alerts and support manual block and unblock of instant payment orders via SPB-Web. Indirect participants inherit operational interruption risk and need contingency plans agreed with their direct participant.

Secondary source checked 16 Sep 2026 transaction monitoring instant payments
Brazil In force High impact
In effect

Mandatory restriction lookup before opening any account

Resolucao BCB n. 475/2025 + IN BCB n. 661/2025 (BC Protege+) ·Res. BCB 475/2025; IN BCB 661, de 11/09/2025 ·Banco Central do Brasil

Before opening a checking, savings or payment account — or changing the legal representatives on a corporate account — institutions must query the BCB's restriction-communication system.

  • 1 Dec 2025 In force
What it obliges you to do

Onboarding flows must integrate the mandatory lookup, block on a hit, and log the consultation for supervisory review. This is the single clearest mule-account control in the Brazilian package and the one most likely to require an onboarding architecture change rather than a rule tweak.

Secondary source checked 16 Sep 2026 onboarding kyc
Brazil In force
In effect

Scam risk separated from fraud risk in payment arrangements

Resolucao BCB n. 522/2025 ·Res. BCB 522, de 10/11/2025 (altera Res. BCB 150/2021) ·Banco Central do Brasil

Formally distinguishes fraude — manipulation of information, systems or documents — from golpe: social engineering, identity simulation and inducing user error. Both become named risk categories in the arrangement's risk management.

  • 10 Nov 2025 Published
What it obliges you to do

Scam and APP losses must be measured and reported separately rather than bundled into generic operational risk, with monitoring mechanisms, detailed incident recording and periodic information-sharing among participants. This is the reporting-taxonomy change most likely to break existing loss-attribution models.

Secondary source checked 16 Sep 2026 reporting data sharing
Brazil In force High impact
In effect

Mandatory rejection of payments to accounts suspected of fraud

Resolucao BCB n. 501/2025 ·Res. BCB 501, de 11/09/2025 (altera Res. BCB 142/2021) ·Banco Central do Brasil

Institutions must reject — not merely flag — payments destined for accounts under founded suspicion of fraud involvement, across Pix, TED, DOC, boleto and internal transfers.

  • 11 Sep 2025 Published and in force
  • 13 Oct 2025 Compliance deadline
What it obliges you to do

Requires a real-time destination-account risk check inside the payment path, covering checking, savings and prepaid payment accounts — plus a defensible evidentiary standard for what constitutes 'founded suspicion', since a wrongful rejection is itself a customer-harm event.

Secondary source checked 16 Sep 2026 transaction monitoring liability
EU In force High impact
In effect

Verification of Payee mandatory for euro-area PSPs

Instant Payments Regulation ·Regulation (EU) 2024/886, Art. 5c ·European Parliament & Council / EPC

PSPs in the euro area must offer payers a payee-name-to-IBAN check before the payer authorises any euro credit transfer in the EU/EEA — not only instant transfers. The check is free to the payer and returns a four-state result: match, close match, no match, or other.

  • 13 Mar 2024 Adopted by Parliament and Council
  • 5 Oct 2025 EPC VoP Scheme Rulebook in force
  • 9 Oct 2025 Compliance deadline (euro area)
What it obliges you to do

Integrate VoP across every customer channel — online banking, mobile app and API — with the result shown before the payer can initiate. Payment is never blocked: on 'close match' or 'no match' the payer may proceed, and doing so after a warning shifts liability for a misdirected transfer onto the payer. Non-consumer payers may waive the service and opt back in. Expect sub-second response times including in bulk scenarios, and update T&Cs accordingly.

Secondary source checked 16 Sep 2026 verification of payee instant payments liability
Brazil In force High impact
In effect

Fraud marking blocks transacting and new Pix key registration

Resolucao BCB n. 506/2025 ·Res. BCB 506, de 26/09/2025 ·Banco Central do Brasil

Introduces a notification and marking function preventing users flagged as involved in fraud from transacting or registering new Pix keys.

  • 26 Sep 2025 Published
  • 30 Sep 2025 In force
What it obliges you to do

Wire fraud markers into both the transaction path and the key-registration path, and maintain a process to justify and contest markings. Enforcement is backed by daily fines and participant suspension.

Secondary source checked 16 Sep 2026 scheme rules onboarding kyc
Chile In force
In effect

Quarterly fraud dispute reporting and public disclosure

Norma de Caracter General n. 539 ·NCG 539 — archivo E24 ·CMF

Updates the E24 file: issuers report card and electronic-transaction disputes arising from loss, theft or fraud, now including claim-processing changes and cases where payment was suspended or legal action taken.

  • 1 Jul 2025 Issued and in force
What it obliges you to do

Reporting frequency moves from semi-annual to quarterly, and entities must publish aggregated disputed-operation data on their own websites. Supersedes the guidance letters of December 2020 and January 2024.

Primary source checked 16 Sep 2026 reporting
EU In force
In effect

Daily sanctions screening replaces per-transaction screening

Instant Payments Regulation ·Regulation (EU) 2024/886, Art. 5d ·European Parliament & Council

PSPs screen payment service users against EU sanctions lists at least daily, rather than screening every individual instant transfer.

  • 9 Jan 2025 In force
What it obliges you to do

Move sanctions screening off the payment path and onto a daily customer-base sweep, which removes the main latency objection to instant payments but makes list-update freshness and re-screening cadence the new control point.

Secondary source checked 16 Sep 2026 instant payments transaction monitoring
EU Agreed High impact

Payee verification extended to all credit transfers, with refund liability

PSR — Payment Services Regulation ·PSR Arts. 50 and 57 ·European Parliament & Council

PSR extends name-to-IBAN verification beyond the Instant Payments Regulation's scope to all credit transfers, and attaches a refund obligation where a PSP's failure to perform the check causes a defective transaction.

  • — Application — 27 months after entry into force Dependent on unconfirmed OJ publication date.
What it obliges you to do

Where the check is not performed and the payment goes astray, the payer's PSP refunds without delay, with a right of recourse against the payee's PSP or the payment initiation service provider where the failure was theirs. Reported to apply 27 months after entry into force — six months later than the rest of the PSR.

Secondary source checked 16 Sep 2026 verification of payee liability
EU Agreed High impact

Mandatory transaction monitoring and PSP fraud data sharing

PSR — Payment Services Regulation ·PSR Arts. 83, 84 ·European Parliament & Council / EBA

PSR requires risk- and behaviour-based transaction monitoring systems, staff and customer fraud training, and creates a structured arrangement under which PSPs may exchange specified fraud information consistent with GDPR.

  • — Application — with the rest of the PSR
What it obliges you to do

Note the data-sharing provision is permissive, not mandatory — PSPs 'may' exchange information. Sources indicate retention of up to five years after an incident. The monitoring obligation is mandatory and behaviour-based, which in practice means device and behavioural signals alongside rules. No EBA Level 2 RTS dates for transaction monitoring, fraud data sharing or IBAN-name matching have been published in any source checked.

Open question

EBA Level 2 RTS timetable is the single biggest unknown for implementation planning. Watch the EBA consultation register.

Secondary source checked 16 Sep 2026 transaction monitoring data sharing
EU Agreed

PSD3 transposition and re-authorisation of e-money institutions

PSD3 — Payment Services Directive 3 ·PSD3 Arts. 44, 49 ·European Parliament & Council

PSD3 repeals PSD2 and the E-Money Directive. EMIs become a sub-category of payment institution and require re-authorisation. Transposition is reported at 21 months from publication.

  • — Transposition — 21 months after publication
What it obliges you to do

Existing PSD2/EMD2 authorisations remain valid if compliance documentation is submitted within 27 months of entry into force. Third-party providers of services to PSPs — including SCA technology suppliers — may be liable where their systems contribute to fraud in the payments chain, and must be covered by detailed written agreements.

Secondary source checked 16 Sep 2026 liability

How to read this

Each entry cites its sources and carries a verification level. 'primary' = checked against the regulator's own published text. 'secondary' = sourced from law-firm or specialist analysis; article numbers and entry-into-force clauses should be confirmed against the primary text before compliance sign-off.

This tracker is published for information only. It is not legal advice, and it is not a substitute for reading the instrument or taking qualified counsel in the relevant jurisdiction. Dates and article references change; verify against the primary source before acting.