Revolut Ltd · DRN-6183059

The complaint Miss H complains that Revolut Ltd won’t refund money she lost when she was a victim of a scam. What happened Miss H was contacted by someone who represented a recruitment company. Miss H had said that she was looking for work and therefore this wasn’t unexpected. Following this initial contact, the conversation moved to a messaging application where she was offered a job opportunity involving writing reviews on websites with the aim of boosting its popularity and online rankings. So, she proceeded. She was told to open an account with Revolut and send multiple payments to various bank accounts as instructed by the scammer. However, she did not receive any of the promised returns or payments. She believes Revolut could have prevented the fraudulent transactions. As such, she is requesting a full refund of the amount lost. Miss H has also raised the point that she has borderline personality disorder (BPD) which impacts her cognitive thinking skills and as such made her more susceptible to the scam and inability to identify the red flags. Miss H raised her complaint with Revolut who looked into her concerns. It said that it does not believe it should be held liable for Miss H’s loss. It explained that appropriate warnings were presented to her at the time of the transactions, and that she proceeded despite these alerts. Revolut also notes that, in its view, Miss H was not entirely transparent in her responses to the warnings provided. Furthermore, Revolut believes that she failed to carry out sufficient due diligence in verifying the legitimacy of the job offer before making the payments. Miss H referred her complaint to our service. Our investigator agreed that Revolut ought to have recognised the transactions as suspicious and taken further steps to intervene. He recommended that Revolut should refund some of the transactions but felt a 50% deduction was warranted having considered Miss H’s role in what happened. As such he recommended that the liability should be shared. Revolut agreed with the investigator’s view but Miss H disagreed. She said her BPD hadn’t been taken into consideration but that it ought to have been as she wasn’t able to identify any red flags. Therefore. she didn’t feel it was fair that a 50% reduction had been applied and so, the case was passed to me to consider. I issued my provisional findings on 26 February 2026 where 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. In broad terms, the starting position in law is that a bank is expected to process payments that their customer authorises them to make. It isn’t disputed that Miss H knowingly made

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the payments from her account and so, I’m satisfied she authorised them. Therefore, under the Payment Services Regulations 2017 and the terms of her account, Revolut is expected to process Miss H’s requests, and she is presumed liable for the loss in the first instance. However, taking into account the regulatory rules and guidance, relevant codes of practice and good industry practice, there are circumstances where it might be appropriate for Revolut to take additional steps or make additional checks before processing a payment to help protect customers from the possibility of financial harm from fraud. The question then arises whether Revolut ought reasonably to have held such suspicions or concerns in relation to Miss H’s payments - and if so, what might’ve been expected from a proportionate intervention at that time. Further to that, where there is an interaction between a customer and a bank before several payments are processed, as there was here, I’d expect Revolut, as an Electronic Money Institution (EMI) to take reasonable steps to understand the circumstances of that payment. So, taking all of this into account, I need to decide if Revolut acted fairly and reasonably in their dealings with Miss H when she made the payments. Specifically, whether it should’ve done more than it did before processing them – and if it had, would that have made a difference. I also need to decide if Revolut could’ve reasonably recovered the lost funds. So, the starting point here is whether the instructions given by Miss H to Revolut (either individually or collectively) were unusual enough to have expected additional checks to be carried out before the payments were processed. When considering this, I’ve kept in mind that EMI’s process a high volume of transactions each day. And that there is a balance for Revolut to find between allowing customers to be able to use their account and questioning transactions to confirm they’re legitimate. Miss H opened her account with Revolut 14 February 2025 which was the same day as the scam commenced. As such, it could be argued that this would have made it difficult to detect uncharacteristic payments (given the lack of account history). However, I don’t agree that this prevents Revolut from appropriately identifying suspicious activity. I also have to take into consideration other factors. Having considered the transactions Miss H made, I am satisfied there was enough about the characteristics of transaction 12 and the activity on the account that ought to have been concerning, such that Revolut ought to have considered if Miss H was at risk of financial harm. I say this because by this stage Miss H had seven successful payments that day and had attempted a further which had failed. While the payments were not of a significant value, there were several new payees set up on the account and multiple transactions sent to each in quick succession. As such, I think it is reasonable to conclude, this was an unusual pattern of spending, and it demonstrated all the hallmarks of a job scam. I have also considered payment 11 made on 16 February 2025 at 15.41 for £99.99 (which failed). On this payment Revolut asked Miss H why she was making the payment and Miss H said, “I am buying or renting goods and services”. Miss H was then asked what she was buying and she confirmed “work related services”. Miss H then cancelled the payment. However, 10 minutes later Miss H proceeded to payment 12 which was successful. So, taking into consideration what Revolut knew from this interaction and the previous transactions, I am satisfied it ought to have intervened on payment 12. I have considered what intervention I think would have been proportionate given the risk it presented. Having done so, I am satisfied a more robust intervention was required. For example, suspending further payments and engaging with Miss H through its in-app

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messaging system to conduct a more detailed review by asking open and probing questions to establish the risk and potential scam Miss H was falling victim to. And to provide an appropriate warning. I accept that this relies on the accuracy of any information provided by the customer. While Miss H didn’t provide accurate answers to Revolut on previous interventions, at this point Revolut was already on notice that Miss H’s answers were consistent including “work related services” along with account activity which supported the fact she could be falling victim of a job scam. As such, I am satisfied Miss H ought to have been provided with a warning tailored to job scams. I am satisfied that a more robust intervention would have unveiled the scam at this stage. I say this because on payment 11, Miss H had already revealed she was paying for “job related services” and then declined the payment.. Therefore, I am satisfied by payment 12, if Revolut had intervened in the way I have highlighted above (through human intervention), with effective questioning, I am satisfied Miss H would have revealed that she was making the payments for her job – that she had started after being contacted via a messaging application which required her to review websites. Given Revolut’s familiarity with job scams that had become increasingly prevalent by this point, as well as general scam trends that Revolut ought reasonably to have identified Miss H was being scammed considering these ‘red flags’. It follows that I would’ve expected Revolut, as a financial expert to have warned Miss H that it was likely she was being scammed. And advised her not to proceed with making any further payments or, at the very least, recommended that she carry out further checks on the legitimacy of the job opportunity before doing so. I’ve no reason to think Miss H wouldn’t have heeded the advice of Revolut. It follows that I think Revolut failed to protect Miss H from the loss she suffered from the point of Payment 12 (£99.99 made on 16 February 2025 at 3.51pm). The total loss Monzo could’ve prevented is £3,782.16. I’ve given thought to whether Miss H should bear some responsibility by way of contributory negligence. Having done so, I don’t think that would be fair here. This is because Miss H was on the look out for employment and thought her details had been found legitimately. She also hadn’t found anything online that indicated the opportunity wasn’t legitimate. I’ve also taken Miss H’s BPD and the impact this had on her decision making into consideration and seen medical evidence of her diagnosis. Because of this, I think Miss H was more susceptible to this type of scam and wouldn’t necessarily have identified the risks or ‘red flags’ here – including the unusualness of having to make payments to earn money. And so, while there may have been some misguided trust given to the scammer, I don’t think Miss H’s actions were negligent to the point whereby it would be fair to reduce the award in these specific circumstances. But instead, I think Revolut’s failure to undertake an appropriate intervention caused Miss H’s losses. So, I think Revolut should refund £3,782.16 and pay 8% simple interest to recognise the loss of use of money she suffered during this time, calculated from the date of each payment to the date of settlement. My provisional decision My provisional decision is that I uphold this complaint in part. I intend to direct Revolut Ltd to: • Refund £3,782.16 • Pay 8% simple interest calculated from the date of each payment to the date of settlement - less any tax lawfully deductible.”

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Revolut didn’t respond to my provisional findings. Miss H did respond and said she felt Revolut hadn’t done enough to recover her funds at the time and if it had she would have received the full money back she lost to the scam. 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, my provisional findings remain the same, but I will address the further point Miss H raised. In the investigator’s findings he explained that Revolut had provided evidence to show it had contacted the third-party bank to attempt recovery. However, it didn’t respond, so recovery failed. Having reviewed the evidence submitted, I can see Revolut did contact the beneficiary bank, although it wasn’t immediately. However, I have given considerations to the circumstances of these payments, and even if Revolut had done so, immediately, due to the delays from the third party responding, the nature of some of the payments and nature of the scam, I am satisfied recovery of funds was highly unlikely. As such, my decision remains the same. Putting things right I direct Revolut to: • Refund £3,782.16 • Pay 8% simple interest calculated from the date of each payment to the date of settlement less any tax lawfully deductible. My final decision My final decision is that I uphold this complaint and direct Revolut Ltd to pay Miss H how I have outlined in my findings above. Under the rules of the Financial Ombudsman Service, I’m required to ask Miss H to accept or reject my decision before 20 April 2026. Jade Rowe Ombudsman

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