Revolut Ltd · DRN-6255498

The complaint Mrs S complains that Revolut Ltd (‘Revolut’) declined to reimburse her when she lost money as a result of a scam. What happened I wrote to both parties in February 2026 with my provisional findings on this complaint. The following is an extract of that provisional decision. “In November 2023, Mrs S was contacted on a withheld number by someone who claimed to be from the fraud team at Mrs S’s bank. Unfortunately, Mrs S was talking to a fraudster. After confirming her name, and asking her security questions, they told her that her bank account was at risk. They said they had detected unusual activity on her account and that her card had been used in the area where she lived, and around the same time it had been used in a location which was many hours travel away. They told her they were concerned because they knew she had a lot of money in her account. Mrs S said that she was persuaded she was speaking to her bank as the caller knew numerous details about her account, including that she had recently used her card in the area she lived in and that she had a larger than normal account balance. Mrs S said the caller then asked her to check her bank account to make sure there was no activity she did not recognise, and to check that she still had her card in her possession. She explained that they told her they would need to close her current bank account as it was now compromised. They said she could do this in branch the following week, but they would need her to move her money in the meantime. They told her funds could not remain in a closed account, so they could either send the funds to another account in her name, or send her a cheque which would take 10-15 days. They said they legally had to ensure that customers had at least 10% of their money available to them, so she could not wait until the following week to simply set up the new account. The caller suggested Mrs S set up an account with Revolut. Mrs S said she already had an account with Revolut, so she transferred all of her funds from her bank account to her Revolut account - £12,850. From there Mrs S was told they were setting up a temporary account that she could transfer 10% of her Revolut balance into to make sure she had some money until her new bank account could be opened. She was persuaded that her bank was liaising with Revolut about setting up the payment and asked her to do certain things including asking her to upload a copy of her driving license to the Revolut app to confirm they had authority to liaise with her bank. Mrs S was put on hold numerous times and began to feel concerned so she called her bank from another phone. Mrs S then discovered she had not been speaking with her bank but had instead been speaking to a fraudster. She said she then found out that there had been three attempted transactions from her Revolut account which had been declined, but £5,000 had left her Revolut account. This table shows the payment and payment attempts Mrs S made from her account with Revolut, following the credit of £12,850 from her bank account.

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Date Time Transaction Amount 10 November 2023 17:30:49 Debit card payment to cryptocurrency exchange ‘N’ - DECLINED £12,850 10 November 2023 17:35:06 Debit card payment to cryptocurrency exchange ‘N’ - DECLINED £5,000 10 November 2023 17:35:11 Debit card payment to cryptocurrency exchange ‘N’ - DECLINED £5,000 10 November 2023 17:38:43 Debit card payment to cryptocurrency exchange ‘N’ - COMPLETED £5,000 After realising what had happened, Mrs S moved the remaining £7,850 back to her bank account. She asked her bank and Revolut to consider reimbursing her the £5,000 she had lost as a result of the scam. Revolut declined to reimburse Mrs S’s losses on the basis that it had attempted to raise a chargeback to recover the funds, but that this would not be successful because it appeared that Mrs S had authorised the transaction. Unhappy with this answer, Mrs S brought her complaint to this service. One of our investigators looked into what had happened and they recommended that both her bank and Revolut ought to have found the payment to be unusual and out of character for Mrs S’s account. They suggested that if either firm had made further enquiries the scam would have come to light and Mrs S would not have incurred the losses she did as a result of the scam. But they thought Mrs S ought to bear some responsibility for the loss too. This was because they thought both her bank and Revolut should have prevented her loss but she ought to have done more to verify who she was speaking to, as there were some red flags which should have alerted her to the fact something was not right. So our investigator recommended that Revolut refund one third of the £5,000 loss, plus 8% simple interest from the date of the loss to the date of the settlement. Revolut agreed to the findings, but her bank did not. As such, the cases were both passed to me to decide. I had reached a provisional decision with regard to the case against her bank, which suggested my thoughts at the time were that each bank should share in the liability for Mrs S’s loss. However, after her bank’s response, I am minded to change the outcome to say that they are not liable for the loss in this case. Broadly speaking, this is because the funds from her bank were going to an existing account in her own name with Revolut as a single transaction, and I am not persuaded that it would have been clear to her bank that she was at risk of financial harm from fraud. And as this would impact the redress in this case, I am writing this provisional decision. What I’ve provisionally 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. 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:

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• 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. Were the payments authorised, and should Revolut done more to protect Mrs S from financial harm from fraud? I want to assure Mrs S and Revolut that if I don’t address every point that’s been raised, it’s not because I haven’t thought about it. I have considered everything that’s been said and sent to us. But, I’m going to concentrate in this decision on what I think is relevant and material to reaching a fair and reasonable outcome. It appears to be common ground that: • Whilst Mrs S was tricked into doing so, she did authorise the transaction from her Revolut account; and • Revolut should have done more to protect Mrs S from financial harm from fraud – in that both parties agreed to our investigator’s view of this complaint. So, I will not cover this off again in depth. But, for completeness, I will briefly cover both points. I do think that the payments were authorised – even though Mrs S was tricked into making them. Authorisation can mean that Mrs S knowingly took all of the steps to make a payment – or can mean, such in this case, that she told Revolut that she wanted payments to happen. I understand that she thought that she was authorising her bank and Revolut to communicate, but the screen she was presented with was clear that she was authorising a payment to the named cryptocurrency provider, and she then followed the steps necessary to make the payment. This would mean in the first instance that she would be liable for her losses – so I have gone on to consider whether there was more that Revolut ought to have done to protect her from financial harm. On this second point, I will say that I do think that the payments demonstrated that Mrs S was at risk of financial harm from fraud – the pattern of a large payment in, followed by three attempted payments and one successful payment to cryptocurrency were not only unusual and out of character for Mrs S’s account, but represent a known pattern of fraudulent transactions. It seems that Revolut agreed – as they blocked the first three attempted payments, and accepted our investigator’s view of the complaint. So, I agree with our investigator that Revolut ought to have provided a human intervention in this case. I also agree that I think such an intervention could have prevented Mrs S’s loss here. I say this because Mrs S was not coached to lie to Revolut – and says she only answered questions incorrectly within the in-app warnings as she was genuinely confused, not as a means to mislead the bank. So I think that if Revolut had asked Mrs S what was going on, she would

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have answered them honestly. Mrs C thought she was talking to her bank, but this type of scam - ‘safe account scam’ – is well known within the financial industry and if someone from Revolut had heard what Mrs S thought was happening, it would have been able to quickly identify that this was a scam and stop the payment from going through. So, I do think that based on everything I have reviewed so far, it would be fair and reasonable for Revolut to bear some responsibility for Mrs S’s losses here. Should Mrs S bear some liability for her losses? I’ve thought about whether Mrs S should bear any responsibility for her loss. In doing so, I have considered what the law says about contributory negligence, as well as what I consider to be fair and reasonable in all of the circumstances of this complaint. Having done so, I do not consider that Mrs S should be held liable for her losses. I understand in this case there were some aspects to the scam that with the benefit of hindsight might look like they should have given Mrs S cause for concern in the moment. The fraudster initially told her they were calling from her bank but that she ought to open an account with a different business, Revolut, although she turned out to have an account with them already. It also does not appear that she took steps to independently verify that she was speaking to her bank, even though they were calling from a withheld number. And Mrs S had the opportunity to read a relevant warning about this type of scam when she authorised the payment with her bank. However, my role here is to consider Mrs S’s actions in the moment, not with the benefit of hindsight. And in considering whether Mrs S should bear any responsibility for her loss, some of the things I have considered are as follows: • These types of scams work because the fraudsters are incredibly professional, persuasive and adept at using techniques which place their victims under considerable psychological strain. • Mrs S believed she was talking to her bank because they were able to cite the last four numbers of her card number, and describe a recent legitimate transaction she had made, and so the fraudster seemed to have information that only her bank could have had. • Mrs S had a large amount of money in her account, which had been a gift from her parents. She truly believed she was at risk of losing it all if she did not do as she was told. • As she believed she was talking to her genuine bank, it is understandable that she would simply follow the instructions she was given without questioning them too closely – after all, she thought she was talking to an expert who was there to help her. • Whilst on reflection it might seem strange that the money was going from her bank to her account with Revolut - a different business - it would have been plausible in the moment that the money had to be moved away from her compromised account to keep it safe. • I appreciate too that Mrs S went through some warnings on the Revolut app – including that if someone was guiding her on what to do on the app, they were a scammer. There were also investment scam warnings. I think from the evidence I have reviewed from both Revolut and her bank, and Mrs S’s testimony, that she was not reading these in depth as she was clicking through them as she thought she had to do this to make sure her funds were safe. • The scam came to an end because of Mrs S herself, who as soon as she considered something might be wrong, called her bank and prevented any further loss. I do not believe that the actions of Mrs S were the actions of someone acting carelessly or recklessly, and so I do not think that it would be appropriate to hold her liable for her

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losses in this case. Conclusions Overall, having considered the matter carefully, I am currently minded to say that Revolut should refund the loss in full of £5,000. So, if nothing changes, I will be asking Revolut to pay Mrs S £5,000. I think that Revolut should also pay 8% simple interest per annum on that amount from the date of the payment to the date of settlement.” 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. Mrs S accepted my provisional decision, but Revolut did not. It said, in summary, that the sudden shift to 100% liability for it lacked a transparent or justifiable rationale. It did not think that the reason for waiving liability from Mrs S’s primary bank had been explained and was inconsistent with the original 50/50 split. It also said that Mrs S should bear liability for contributory negligence – as she accepted an inherently implausible proposal from a purported bank representative without taking steps to verify the request through official channels. It said it contesting the outcome and insisted on a more equitable distribution of loss. Removal of liability of loss for Mrs S’s bank I have carefully considered the evidence available to me in both cases, including information and arguments from Mrs S’s bank and from Revolut. I will not rehearse everything that happened on the other complaint as it was about her bank, and not Revolut. But I had contemplated that her bank and Revolut should be equally liable in the first instance, but reached the conclusion that this would not be fair and reasonable in the circumstances of the complaint. This change in outcome for her bank was not simply because the payment went from her bank account to an account in Mrs S’s own name with Revolut. But, when funds do go from one account in one’s own name to another, it follows that the starting point should be that the bar for expecting a financial firm to intervene is higher than if it is going to a totally new payee. With this in mind, the call on whether her bank ought to have intervened had been a close one, and I have decided that it would not be fair and reasonable for it to have intervened. There was a single payment to an established payee (her own account with Revolut), and knowing nothing else about the payment, I did not think it was reasonable for her bank to be expected to intervene in this case. In this circumstance Revolut take on the liability, as they would if the funds had simply originated in the Revolut account before they went to the scammer. I appreciate that this is a change from the 50/50 split, but I think this is the fairest outcome in the circumstances of this complaint. Should Mrs S bear some liability for her losses? I appreciate that Revolut do not agree with me here, but I am still persuaded that Mrs S need not bear responsibility for her losses. I will not repeat everything that I have already outlined above in the extract from the provisional decision. But I will say that I do appreciate there are things that with the benefit of hindsight ought to have given Mrs S cause for concern and prompted her to do more checks before sending the payment, or simply not sending it at all. But I am looking at her actions and thought processes in the moment, not with the benefit of

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hindsight. And in the moment, the scammers used techniques to cause Mrs S to believe she was about to lose all of her money. She was persuaded that she was talking to her bank, and simply took the steps she believed her bank was giving her in order to keep her money safe. So, I do not think it would be fair or reasonable to hold her liable for her loss here. Putting things right To put things right, Revolut must now: • Reimburse the £5,000 Mrs S lost to the scammer; and • Pay 8% simple interest from the date of the loss to the date of the settlement. My final decision I uphold this complaint and require Revolut Ltd to reimburse Mrs S in line with what I have outlined above. Under the rules of the Financial Ombudsman Service, I’m required to ask Mrs S to accept or reject my decision before 23 April 2026. Katherine Jones Ombudsman

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