AI-washing – when AI hype becomes a litigation risk
The Global Fraud Summit in Vienna came at a useful time – shortly after the launch of the new UK Fraud Strategy. It gave ministers a platform to present the United Kingdom as a country trying actively to shape the international response to fraud.
Lord Hanson's keynote speech was central to that message. He emphasised the themes now defining the UK's anti-fraud programme: better use of data, stronger international cooperation, greater public awareness, more support for victims, and closer engagement with private-sector partners. The summit was used to anchor these priorities to concrete mechanisms rather than broad promises.
That matters because fraud is increasingly understood not as a series of isolated scams, but as an industrialised, transnational criminal enterprise. The UK's argument in Vienna was that the response must become more international and more collaborative if it is to keep pace. For businesses, that means this is no longer just a policy story. It is a prompt to assess whether fraud controls, escalation routes and information-sharing arrangements are fit for a more demanding enforcement and cooperation environment.
The clearest example was the launch of the new Global Fraud Task Force with INTERPOL, together with Operation Shadow Storm. The focus is on scam compounds in South East Asia and the networks that support them. The model is practical: intelligence is pooled across jurisdictions to identify infrastructure used by fraudsters – bank accounts, crypto wallets, telephone numbers, social media profiles and other digital touchpoints – and that intelligence is then deployed to support freezes, shutdowns and coordinated raids.
That approach builds on earlier coordinated activity, including raids in South East Asia last year and a January 2026 operation in Nigeria. The point the UK is keen to make is that cross-border fraud can be disrupted if agencies share intelligence earlier and work from a common picture.
This is also where the summit aligned closely with the UK Fraud Strategy. The strategy had already stressed that serious fraud is often rooted overseas and that the UK must work more closely with foreign partners, international bodies and the private sector. Vienna gave that position a more visible international platform and lent it greater operational credibility.
The other striking feature of the summit was how explicitly it positioned business as integral to the anti-fraud response – as a core part of the enforcement model.
The January 2026 Nigeria operation is a good example of this. The coordinated action involving the UK National Crime Agency, the Nigerian Police Force and Meta demonstrates what governments increasingly expect from major companies: intelligence, rapid cooperation and practical assistance in identifying and disrupting fraud infrastructure. Platforms and other large businesses often detect the signals first. If they share those signals lawfully and quickly, intervention can happen earlier.
That same approach underpinned the summit's wider outcomes. A new global public-private partnership framework was launched around a set of familiar but important principles: shared responsibility, proactive and coordinated prevention, lawful information-sharing, victim support, education and innovation. Fraud prevention is being re-framed as something that must be built into systems, products, reporting routes and operational relationships, not left to law enforcement after the event.
The industry accord announced at the summit is where that agenda becomes more concrete. The accord focuses on four broad themes: prevention, cooperation and collective learning, resilience, and public awareness. Behind those headings sits a demanding set of specific commitments.
The commitments point towards stronger verification and detection measures, clearer anti-scam terms and enforcement, better information-sharing, faster collective learning from scam trends, improved internal resourcing, and more systematic consumer education. The underlying message is clear – companies should treat scam prevention as a core operational priority rather than a peripheral trust and safety issue.
There is also a second message running through the accord. The signatories are not only making commitments to each other. They are also calling on governments to make this easier: modernise data capabilities, improve reporting systems, enable more effective cross-border information-sharing, and reduce legal ambiguity that may inhibit proactive anti-scam action.
This is an important point. Businesses appear to be saying that they will do more, but they want clearer rules and greater protection when acting in good faith to detect, prevent or disrupt fraud. This is also an interesting counterpoint to the UK Fraud Strategy, which in effect warned technology and telecoms companies to do more, or face legislation that makes them. Lord Hanson's speech pointed in a more collaborative direction, particularly on lawful information-sharing, though without going as far as a safe harbour offer.
The summit was not only relevant to the eleven companies that signed the accord. It was also a challenge to the wider market. Fraud prevention is increasingly being framed as a shared corporate responsibility across technology, telecoms, payments, marketplaces, advertising, financial services and other sectors that may be used to facilitate or monetise scams.
For many organisations, the practical question is now what stepping up should actually look like. That may include stronger customer or counterparty checks, clearer internal escalation routes for fraud indicators, more mature arrangements for lawful data-sharing, deeper engagement with law enforcement, sharper contractual expectations for suppliers and intermediaries, and more disciplined use of AI and analytics in fraud detection and prevention.
There is also a broader governance point. Once governments and major companies start framing fraud disruption as a shared operational responsibility, boards and senior management will find it increasingly difficult to treat the issue as something owned only by compliance and risk teams.
The summit was a strong piece of UK positioning, but it was more than that. It outlined a clearer model for how governments intend to tackle fraud: international in reach, intelligence-led in practice, and reliant on far deeper cooperation with business. Whether that model delivers will depend on sustained funding, political follow-through and the willingness of more sectors to engage.
The UK wants to be seen not just as talking seriously about fraud, but as helping to organise the response. Businesses should read that as a cue to review their own preparedness now rather than wait for regulation to compel them.
Please do reach out to your Hogan Lovells contacts if you would like to discuss further; we can help you strengthen your governance and controls in readiness for this new fraud prevention agenda.
Authored by Reuben Vandercruyssen.