Revolut Ltd · DRN-6162600

The complaint Mrs M complains that Revolut Ltd won’t refund the money she lost to a scam. What happened The details of this complaint are well known to both parties, so I won’t repeat everything again here. However, in brief, Mrs M saw an advert for a company that purported to be a crypto trading firm that was actually a scammer. I will call this company B. Mrs M made the following payments as part of the scam to a crypto exchange. Transaction Number Date Amount Payment Type 1 28 April 2022 £4,205.96 Card payment 2 3 May 2022 £4,503.66 Card payment 3 10 May 2022 £2,173.43 Card payment 4 10 May 2022 £359.48 Card payment 5 13 May 2022 £4,256.32 Card payment 6 13 May 2022 £4,253.90 Card payment 7 13 May 2022 £433.78 Card payment 8 27 May 2022 €3,390.45 (payment in Euro) Card payment 9 31 May 2022 £2,809.61 Card payment 10 31 May 2022 £2,554.64 Card payment 11 2 June 2022 £3,914.69 Card payment Mrs M realised that she had been scammed when she was unable to withdraw her profits from the scam firm. I issued a provisional decision on 12 March 2026 in which I said the following; “I’ve considered all the available evidence and arguments to decide what’s fair and reasonable in the circumstances of this complaint.

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In broad terms, the starting position is that an Electronic Money Institution (“EMI”) such as Revolut is expected to process payments and withdrawals that a customer authorises it to make, in accordance with the Payment Services Regulations and the terms and conditions of the customer’s account. But, taking into account relevant law, regulators’ rules and guidance, relevant codes of practice and what I consider to have been good industry practice at the time, I consider it fair and reasonable that Revolut should: • have been monitoring accounts and any payments made or received to counter various risks, including preventing fraud and scams; • have had systems in place to look out for unusual transactions or other signs that might indicate that its customers were at risk of fraud. This is particularly so given the increase in sophisticated fraud and scams in recent years, which firms are generally more familiar with than the average customer; • in some circumstances, irrespective of the payment channel used, have taken additional steps, or made additional checks, or provided additional warnings, before processing a payment; • have been mindful of – among other things – common scam scenarios, how fraudulent practices are evolving (including for example the common use of multi-stage fraud by scammers, including the use of payments to cryptocurrency accounts as a step to defraud Mrs M) and the different risks these can present to Mrs M, when deciding whether to intervene. I do not think that the first five payments were large enough or formed a pattern sufficiently indicative of a scam to prompt an intervention from Revolut. That said, I think that when Mrs M made a card payment of £4,253.90 on 13 May 2022, Revolut should have been aware that Mrs M was at a heightened risk of fraud, as it represented over £8,500 sent in the same day, which was unusual and was large enough to have prompted an intervention. I think that an appropriate intervention at that time would have been a human intervention, with Revolut asking questions about the payment in question. Had questions been asked about the payment, I think that Revolut would have been able to highlight to Mrs M that what she was doing had the hallmarks of scam. The scam had many features that were common at the time for crypto scams. It was a crypto investment, fronted by a celebrity, it involved remote access and the need to send crypto from a crypto exchange to a third-party investment platform. So I think that Revolut could have said with a high likelihood, that Mrs M may have been being scammed. So, I think at that point, the scam could have been uncovered had Revolut carried out an appropriate intervention and I don’t think that Mrs M would have sent further funds to the scammer, had that happened.

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I have taken into account that Mrs M remained in control of her money after making the payments from Revolut. It wasn’t lost until she took further steps to forward it on to the scammer. But Revolut should still have recognised that Mrs M was at risk of financial harm from fraud, made further enquiries and issued a warning to Mrs M. And had it done that, ultimately I think it would’ve prevented Mrs M’s loss from the point highlighted above. So I think Revolut can fairly be held responsible for Mrs M’s loss in such circumstances. While I have considered all of the facts of the case, including the role of other financial institutions involved, Mrs M has chosen not to complain about any other firm and I cannot compel her to do so. Also, I do not think it would be fair to reduce Mrs M’s compensation because she’s only complained about one firm, as I consider that Revolut could have prevented the loss, had it carried out a reasonable intervention when there were clear signs that Mrs M could be at risk of financial harm. I should also highlight that neither Revolut, nor her other account providers, intervened during the scam or provided a warning setting out the common features of crypto scams. Should Mrs M bear any responsibility for her losses? In considering this point, I’ve taken into account what the law says about contributory negligence as well as what’s fair and reasonable in the circumstances of this complaint. In this instance, Mrs M did not ignore any relevant warnings, was not promised unrealistic returns and there were no warnings about B at the time that the transactions were made. So overall, I don’t think that Mrs M acted unreasonably or contributed to her own loss. So I do not think that deduction is appropriate in this instance. Recovery of funds I’ve also looked at whether Revolut could or should have done more to try and recover Mrs M’s losses, once it was aware that the payments were the result of fraud. As the payments outlined were card payments, I’ve considered whether Revolut should have tried to recover the money through the chargeback scheme. This is a voluntary agreement between card providers and card issuers who set the scheme rules and is not enforced by law. A chargeback isn’t guaranteed to result in a refund. There needs to be a right to a chargeback under the scheme rules and under those rules, the recipient of the payment can defend a chargeback if it doesn’t agree with the request. Revolut attempted a chargeback for the transactions in question and these were not successful. So I don’t think that it needed to do anything more. “ Mrs M agreed with my provisional decision Revolut did not respond with any additional points. What I’ve decided – and why I’ve considered all the available evidence and arguments to decide what’s fair and reasonable in the circumstances of this complaint. As neither party has raised any additional points I see no reason to change the outcome set out in my provisional decision.

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So in summary I think that Revolut should have intervened more than it did and this intervention would have stopped the scam. I also did not think that Mrs M contributed to her own loss and therefore Revolut should refund all of the payments from the point I think it should have intervened (payment 6). Putting things right For the reasons I’ve explained, I uphold this complaint about Revolut Ltd in part and instruct it to do the following: 1. refund the transactions lost to the scam from and including payment 6 2. Add 8% simple interest annually, from the date the transactions took place to the date of settlement, less any tax lawfully deductible. My final decision My decision is that I uphold this complaint against Revolut Ltd in part and instruct it to do what I have set out above to put matters right, in full and final settlement of this complaint. Under the rules of the Financial Ombudsman Service, I’m required to ask Mrs M to accept or reject my decision before 24 April 2026. Charlie Newton Ombudsman

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