Ensuring regulatory compliance while keeping transactions simple
The E-Payments User Protection Guidelines (EUPG) was introduced to protect users from digital scams.
The guidelines stated that we had to “inform users of any potential risks and implications” before any transaction is made on the app.
If we didn’t, and a user loses money to a scam via the app, we may be financially liable for their losses.
Building new working relationships
UOB’s Group Legal team are highly risk-averse – much more so than Digital Legal, who we usually work with.
For Group Legal, the surest way to protect the bank was to use unambiguous content (i.e. legalese) with compulsory checkboxes – that didn’t quite work for us.
It was a challenge with them initially opting out of meetings, wanting instead to review the work and simply give feedback via email.
After a lot of back-and-forth, I finally managed to bring them into a working session, where we eventually collaborated to reach a solution that met both legal and user needs.
What Legal initially insisted on:
Final design:
Reaching a compromise in design
Noticeable yet undisruptive:
Instead of a compulsory checkbox, we used an infobox – attention-grabbing enough to make users rethink their transaction, yet not too disruptive to a flow that they may go through several times a day.
Presented in the right context:
We moved the information to the payment entry page to let users edit any incorrect details instantly.
Making it simple and helpful:
While we still had to take in Group Legal’s feedback to say “scams” specifically, I simplified the message and softened the tone to focus on helping users, not protecting ourselves.
The message was rolled out to all other payment and transfer flows too, reminding users to be extra careful before they made any transaction – whether it’s paying bills, or even transferring money within their own accounts.
For actions that were deemed ‘high-risk activities’ in the guidelines (e.g. adding a payee, creating a digital token code), users needed to acknowledge the message before continuing.
adding the message to all other transaction journeys:
The bigger win coming out of this project was building a working relationship with Group Legal, and reaching an alignment to try for user-centric content wherever possible. The second phase was much smoother as we introduced real-time notifications across all transactions, even though content compromises were still ultimately necessary.
