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Quincecare Developments in the Struggle Against Scammers in Singapore: Payment Service Providers and a Duty of Retrieval – Hamblin v Moorwand Ltd [2025] EWHC 817 (Ch)

Damien Teo

(2026) 38 SAcLJ 651

Abstract:
This case comment examines the significance of Hamblin v Moorwand Ltd [2025] EWHC 817 (Ch) in Singapore’s response to authorised push payment (“APP”) scams. It argues that the decision elucidates promising avenues for Singapore law to better protect APP scam victims. Firstly, the extension of the Quincecare duty to payment service providers (“PSPs”) is a natural consequence of the equivalence between banks and PSPs under the Payment Services Act 2019 (2020 Rev Ed). Secondly, the use of derivative actions may offer APP scam victims a principled route to overcome privity barriers associated with the Quincecare duty. Thirdly, the emerging concept of a retrieval duty may further strengthen private law protections against modern financial fraud in Singapore.