Revolut Ltd · DRN-6171543

The complaint Miss P complains about Revolut Ltd. She says that Revolut didn’t do enough to protect her when she fell victim to a romance scam and would like it to refund her the money she has lost as a result. What happened In 2021, Miss P met ‘V’ on a dating website. He said that he was a lonely person, without family, and was currently working in Nigeria but lived in the UK and planned to return as soon as possible. Over a number of years, V manipulated Miss P into sending extraordinary amounts of money to him, while feeding her elaborate lies. Unfortunately, Miss P was so taken in by V, who she had never met, or had a video call with, that she believed what she was being told, and continued to send money to him while withholding information from family and friends about what was happening. Initially, Miss P was sending funds to V from her accounts with H, S and R, before V told her that it would be easier to send funds via an account with Revolut. On opening the account, Miss P told Revolut that she would be using it for spending abroad, overseas payments and transfers. Between May 2022 and November 2023, Miss P made 37 payments totalling £189,422 to two third-party accounts. Miss P accepted that she has been scammed when her family staged an intervention into what she was doing and made a complaint to Revolut about what had happened. Revolut didn’t uphold her complaint, so she brought it to this Service. Our Investigator looked into things but didn’t think that Revolut needed to refund her the money she had lost and didn’t uphold her complaint. Miss P and her representatives asked for a final decision, so the complaint has been passed to me. 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. Having done so, I have decided not to uphold this complaint. I know this will be very disappointing for Miss P, especially as there is so much money at stake, and I know this has been a very upsetting time for her.

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I should start by saying that although I am not upholding this complaint, I am naturally sympathetic to Miss P’s situation, and I do not doubt that she has been the victim of a long running and especially cruel scam, and I’m sorry she’s gone through such a difficult experience. However, my role here isn’t to establish if Miss P has been scammed or not – it is very clear that she has been. But to find if Revolut can reasonably be held responsible for her losses. And I’m afraid that I don’t find that it can. I will explain why. In broad terms, the starting position at law 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 (in this case the 2017 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; • Have acted to avoid causing foreseeable harm to customers, for example by maintaining adequate systems to detect and prevent scams and by ensuring all aspects of its products, including the contractual terms, enabled it to do so; • 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 consumers) and the different risks these can present to consumers, when deciding whether to intervene. Looking at the payments Miss P made from her account, which span a period of 18 months, I think that on the initial payment, Revolut should have presented her with a written warning broadly covering scam risks. I think this would have been an appropriate intervention at the time as the account was new, and an established usage pattern hadn’t yet been formed. Miss P had also told Revolut that this kind of payment was what the account would be used for. However, for me to uphold this complaint, I would have to also find that Miss P would have taken such a warning on board – and I’m afraid that I don’t think that she would have done. By this point, Miss P had already been speaking with V for over six months – and I can see that during this time, there had already been several issues where V had managed to persuade her of his legitimacy, even though I do not think the excuses and situations he was telling her about were at all plausible. When Miss P questioned some earlier payments, V was able to persuade her to keep sending money – and to open the account with Revolut in

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the first place. I’m aware that he also told her what to say should she be questioned, and she was completely taken in by him by this time. Looking at the rest of the payments, while in total they represent a huge amount of money overall, they were only sent to two payees and spread out over a period of 18 months. I don’t think that the payments would have looked suspicious or unusual to Revolut, and they quickly began to look ‘normal’ for Miss P. I also doubt that Miss P would have responded positively to any other warnings provided given how invested she was in her supposed relationship with V. I’m aware that although she was questioned by family and friends on several occasions, she did not admit to them the extent of what was going on – and had borrowed funds without saying what the true purpose was, as well as selling items of significant value. I also don’t think that there was anything that Revolut could have done to try and recover Miss P’s funds either – the scam wasn’t reported to Revolut until over a year later, and the recipient banks didn’t respond to Revolut when it contacted them. But in all likelihood, the funds would already have been moved on by the scammer very quickly, and I find it very unlikely that any funds would remain to be recovered even if Miss P had reported the scam earlier. I am very sorry for what has happened to Miss P. I know that she has been cruelly treated by the scammer. However, her losses haven’t been caused by Revolut, but by the scammer. And I don’t find that it needs to refund her. My final decision I don’t uphold this complaint. Under the rules of the Financial Ombudsman Service, I’m required to ask Miss P to accept or reject my decision before 31 March 2026. Claire Pugh Ombudsman

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