UK isn't a good example since they don't have fraud protections in place. This bill needs to into effect before the banks are on the hook. https://bills.parliament.uk/bills/3326
Most banks are signed up to the "Authorised Push Payment Scam Code" and cover fraud, however it's not a legal requirement.
But all banks, of course, have a level of fraud protection in place (just not the legal obligation to replace funds from a scam and compensate/reimburse victims).
It's also worth noting that this is a legal decision, and not a technology issue.