By Jane Le Pla, Consultant, LCP
Increasingly, fraud is occurring without any transfer request at all – from attempts to submit fraudulent bank detail changes, to identity theft used to access online services, to fraudsters posing as scheme administrators or employers. These cases often happen quietly behind the scenes but can be just as damaging for members and for schemes.
The FCA and TPR relaunched ScamSmart in 2024, yet campaigns visible to members remain scarce. In this blog, we explore what trustees can do to help identify and prevent these risks.
A snapshot of our activity in 2025 gives a clear sense of scale. Our specialist Scams Group reviewed 231 transfer cases, up from 182 the previous year. Of these, 101 were identified as having amber flags – including 35 involving high charges or high-risk investments – and 17 were considered red flag cases. It really shows why staying alert and having a clear process matter.
Staying vigilant against pension scams
The Pension Scams Industry Group (PSIG) revised its Code of Good Practice and Interim Practitioner Guide in 2023 to help trustees and administrators align with the 2021 Transfer Regulations. The Code provides best practice guidance to trustees on how to identify transfer requests that may be fraudulent or a scam, aiming to protect members through robust checks without creating barriers.
The Pensions Ombudsman (TPO) has been clear that weak processes equal risk. TPO expects trustees to take “reasonable steps” to prevent loss: keeping records, asking the right questions, and making sure every decision can be justified.
And what about members themselves? It starts with better communication. Administrators and Trustees need to highlight red flags as defined under the 2021 Transfer Regulations clearly and point people to trustworthy, impartial advice.
Recognising and acting on scam risks
As part of our administration service, we act quickly but thoughtfully when we spot potential scam risks. We prioritise real conversations – picking up the phone is the best way to listen, understand concerns, and reassure members before panic or pressure sets in.
We also make sure the right people are involved: experts who understand the technical detail and can communicate clearly, without jargon, and provide patient and supportive guidance. If warning signs are there, we can point members to MoneyHelper’s pensions team. They’re independent, free, and brilliant at cutting through the noise so people can make informed decisions.
Scams are getting more convincing, so it’s important to train administration teams and review processes. Stay tuned to updates from TPR, FCA, PSIG and the Pensions Scams Action Group, who are now working more closely with law enforcement and embedding intelligence experts to spot and disrupt scam networks earlier.
Trustees and administrators play a vital role in protecting members from scams and fraud. Fraud prevention is most effective when it’s embedded across governance frameworks, not treated as a single policy or process. It’s important to make sure ScamSmart messaging and links are visible across all member touchpoints, including annual statements, scheme websites, and newsletters.
How proactive administrators can help
Scams are not limited to transfer requests. Fraud risks exist across the entire member journey – whether someone is retiring, drawing benefits or completely unaware that their pension could be targeted.
At LCP, as part of our administration service, we monitor for all types of suspicious activity, including attempts to intercept payments, identity theft, and transfer out scam activities.
Our approach combines proactive checks, secure communication channels, and rapid escalation when anomalies appear. By embedding fraud awareness into every process, not just transfers, and through training and reviewing cases through discussion and learning from experience, we help create a stronger safety net for members and their pensions.
We also follow the principles of TPR’s Pledge to combat pension scams, ensuring our processes reflect best industry practice for member protection and scams prevention.
Ultimately, protecting members from scams and fraud is a responsibility shared by Administrators and Trustees. Trustees who embed robust processes, keep communication clear, and stay alert to emerging threats can significantly strengthen protection and reduce the risk of financial harm.
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