The Shared Responsibility Framework: When Banks and Telcos Pay Scam Losses

What the Shared Responsibility Framework is

The name sounds like a single law. In practice it is a principle that different places apply in different ways: when a scam payment goes through, the question is who failed. If the bank or the telecom did its job and you still sent the money, the loss is usually yours. If the bank or telecom missed something it was supposed to catch, part of the loss can come back to you.

The clearest way to see the principle at work is in the responsible gambling programs that licensed operators run. These are not reimbursement schemes, but they show the same logic: the operator carries part of the duty to protect the customer, not just the customer alone.

The programs at two operators in the region, alongside the approach of Singapore's regulator, show what this looks like.

What that means for you in practice: if you are gambling at a licensed venue in the region, you can usually do the following.

• Ask staff for responsible gambling information
• Ask to be referred to professional help
• Ask to be excluded from the property

Those requests are part of the operator's duty, and they are free.

The reimbursement side works the same way. A bank that processes a transfer has a duty to flag obvious scam patterns. A telecom has a duty over the numbers and messages it carries. When one of them fails, the framework is what decides how the loss is split. When neither fails, there is nothing to split.

What the framework does not cover

This is where most people get a nasty surprise. The framework is narrower than it sounds.

Land based casinos. The responsible gambling programs that sit alongside these schemes do not cover in person casinos. PlaySmart states plainly that its BetGuard coverage does not cover land based (in person) casinos⁴. If your loss happened at a physical casino cage or table, the framework is not the route.

Overseas hosted betting and lottery sites. Chinese official guidance notes that online lottery scam websites are mostly hosted overseas, which makes rights protection difficult⁵. If the operator is outside the jurisdiction, there is often no local entity to hold responsible, and the framework has nothing to bite on.

Fiscal matters. Timor Leste's Decree Law No. 6/2016 on games does not apply to fiscal matters, namely the tax on game prizes⁹. Tax on winnings sits outside the gaming rules, so a dispute about prize tax is not a framework dispute.

People excluded from a service by law. Japan's JRA admission ticket and reserved seat reservation service bars people who are subject to insurance under the Act on Securing Compensation (Act No. 144 of 2013) from becoming members¹⁰. If you are in that category, you cannot use the service at all, so there is no transaction for the framework to cover.

Unclaimed money. Several operators set deadlines after which money is simply gone. A Dividend or Refund not collected within 60 days of the relevant match is forfeited¹¹. Singapore Pools says any refund not claimed within the stated period shall be forfeited¹², and an unclaimed balance is forfeited five years after account closure for excluded account holders¹³. If you leave money sitting, the framework will not rescue it later.

Transfers you confirmed yourself. On multi player poker products, once the amount and the recipient username are confirmed, the transfer is irreversible and the company is not responsible for loss caused by transferring to the wrong account¹⁴. The same logic runs through most scam reimbursement decisions: a confirmed transfer is treated as your decision.

Instructions given through a card. Once an instruction to bet, withdraw or transfer funds is given via the Smart Card, it cannot be changed or withdrawn¹⁵. If you gave the instruction, you cannot unwind it.

Errors you did not report in time. If a Betting Account holder identifies an error but fails to notify the Club within 60 days of the day the error was made, the Club and the Operator are discharged from any obligation to adjust the account¹⁶. Time limits are strict, and they run from the error, not from when you noticed it.

Funds you did not verify. For online fund transfers to e Cash, a member must verify the status of the transferred fund within the time given when the operator deems fit, failing which the fund will be refunded without prior notice¹⁷. The operator also sends an SMS notification, and the member should check with the operator if no SMS arrives¹⁸. If you ignore the notification, the money can move back without you.

Settlement failures. If settlement fails for reasons not attributable to the company, such as an account freeze or a bank registration error, winnings may be recharged to the account balance¹⁹. That is a return of funds, not compensation.

Lost or damaged cards. A lost card must be reported in writing to the Club immediately, and a damaged card must be returned immediately for replacement. The Club may refuse a damaged card for any use and may charge a replacement fee at its sole discretion¹⁵. Card problems are your responsibility to report.

The pattern across all of these: the framework protects you when the institution failed. It does not protect you from your own confirmed instructions, missed deadlines, or an operator sitting outside the jurisdiction.

How a claim actually runs

If you are scammed and want the framework to apply, the practical steps look like this.

Report immediately. The single biggest factor in any reimbursement decision is speed. Money that has not yet left the banking system can sometimes be stopped. Money that has been withdrawn in cash usually cannot.

Put it in writing. Verbal reports are hard to rely on later. A written complaint creates a record with a date on it.

Expect a wait. Where a formal complaint process exists, the operator's written answer should be communicated within four working days of the formal submission of the complaint. For disputes involving credit or debit cards, app based withdrawals or bank transfers, the response time depends on the investigation and on information requests to the relevant bank or entity³. In other words, card and transfer disputes take longer than four days, because a second institution has to be contacted.

Keep your own evidence. Screenshots of the messages, the transfer confirmation, the account number you sent to, and any warning the bank showed you before you approved the payment. The warning screen matters most: if the bank warned you and you proceeded, that is usually the end of the reimbursement argument.

Check the deadlines that apply to your account. The 60 day error notification window¹⁶, the 60 day dividend and refund window¹¹, the five year unclaimed balance rule¹³, and the verification window on transferred funds¹⁷ all run on their own clocks. None of them pause because you are upset.

Ask about exclusion if you want to stop. If the problem is your own gambling rather than a scam, the exclusion procedure at a licensed operator² and the patron education and help services offered by regulators⁸ are the practical routes. They are free and you do not need a lawyer.

A worked example using the figures above: you transfer money to a betting account, the operator sends an SMS notification, you do not check it, and the operator later refunds the fund without prior notice because you did not verify within the time given¹⁷. You have not been scammed, but you have also not been reimbursed, because the framework only steps in when the institution failed, and here it did not.

Cambodia's suspension of online casino betting

Cambodia is the clearest live example of a government deciding that the online side of casino gambling has become too hard to police.

Online gambling operations at all casinos nationwide are suspended from October 2026⁶. The suspension applies to online gambling activities operated or broadcast from casino premises, while ordinary casinos will not be closed⁶. The government describes the suspension as temporary, and it is being used to review and improve the regulatory mechanisms⁶. No end date has been announced²¹.

The order came from Prime Minister Hun Manet, and it covers all casino based live online betting from October²¹. The government has said that online gambling and other betting activities have already been suspended, effective from the beginning of October²². The stated reason is that casino linked online gambling was unmonitored²³.

This is not Cambodia's first attempt. All kinds of online and arcade gambling had to end by the end of 2019 under an earlier deadline²⁴. The current suspension is narrower in one way and broader in another: it targets the online operations attached to casinos rather than the casino floors themselves.

For a visitor or resident, the practical effect is simple. From October 2026, casino operated online betting is suspended across Cambodia, whether you are sitting in a casino or logging in from a hotel room. The physical casino floors are not being closed⁶. If you have an account with a casino linked online product, it is suspended, and a balance is not paid out on demand.

The suspension is described as temporary, and it applies to online gambling activities operated or broadcast from casino premises, while ordinary casinos will not be closed⁷. The government says it will use the pause to review and improve the regulatory mechanisms⁶.

If you are dealing with a scam rather than a licensing change, the practical routes are covered in what to do after a gambling scam and where to report a gambling scam in Asia. If you want to know whether a site is licensed at all, see licensed vs unlicensed online casino.

The Phnom Penh Declaration and the numbers behind it

For an ordinary reader, the takeaway is not the diplomacy. It is that cross border scam money is now a priority for several governments at once, which means reporting early is more likely to be acted on than it was a few years ago. It also means the online casino products attached to Cambodian casinos are the ones being switched off first, because that is where the unmonitored money moved.