Wise Payments Limited · DRN-6152064

The complaint Mr H complains that Wise Payments Limited unfairly refuses to refund him money he lost in an investment scam. Mr H is being represented, but for ease of reference, I’ll just refer to Mr H. What happened Mr H says he wanted to invest some money. He was not experienced in investment, but he found a website for an investment firm that interested him and he left his contact details. He thought the website looked highly professional and he conducted some research, such as checking online reviews. In around June 2025, he was contacted by representatives of the investment company and he was persuaded to invest. Mr H was asked to download and install remote access software, which he did. He made a small investment with the scammers for a few weeks, and this appeared to generate reasonable profits. In around 14 July 2025, Mr H was persuaded to invest substantially more. He says he was persuaded to apply for loans with the aim of investing the money he was loaned. He took out a loan on 14 July 2025 and another on 17 July 2025, both for £20,000 and the money was received into his bank account, before being sent on to his account with a different bank. From there, one payment of £20,000 was made to his account with Wise, which he had set up on 4 July 2025 and the money was then moved on from Wise to another account in Mr H’s name, although he says this account was not set up or controlled by him. The investment account balance appeared to be growing but when Mr H came to withdraw money from the investment account, he says he was met with obstacles, such as further payments being required before any sums could be withdrawn. It was at this point Mr H came to realise he had been the victim of a scam and the investment company had been fake. He informed Wise he had been scammed on 22 August 2025. Mr H made one payment from Wise as part of this scam: Date Amount Payment type Destination 18/07/2025 £20,000 Faster payment Overseas bank account in Mr H’s name Mr H considers Wise ought to have done more to protect him from falling victim to this scam. He says the payment on 18 July 2025 ought to have been viewed with suspicion by Wise because the account was newly opened, it received a large credit and it was swiftly paid out. He says Wise should have provided clear scam warnings and encouraged him to research the investment company and if it had done so it is likely the scam would have been exposed. Mr H was starting to realise this might be a scam just before he made the payment from Wise. He had applied for further loans but had cancelled them because he was reluctant to invest more. The scammers put pressure on him to make this payment, claiming he needed to invest more otherwise he would jeopardise the money he had already invested. If Wise had intervened, he considers the scam could have been prevented because probing questions would have revealed information that would have been of real concern to Wise.

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Wise does not consider it is responsible for Mr H’s loss. It says this was a newly opened account, so it did not have an indication of what Mr H’s usual account activity might look like. The money was sent on to another account in Mr H’s name. It considers Mr H could have done more to protect himself from falling victim to this scam and that he missed signs this was a fraud, such as being asked to apply for loans in order to invest the proceeds, which is highly unusual. It adds that it was not aware of any vulnerabilities Mr H had at the time. One of our investigators considered Mr H’s complaint, but he didn’t uphold it. He said he thought the payment was unusual and ought to have prompted Wise to intervene in the payment. As part of his investigation, the Investigator listened to recordings of calls between Mr H and one of his banks. These calls took place on 17 and 18 July 2025, when Mr H was trying to send money onwards. The Investigator noted that Mr H had provided his bank with inaccurate information in response to some of the questions it had asked him. The Investigator thought that if Wise had intervened, Mr H would, most likely, have provided similarly inaccurate answers. He said it appeared Mr H had been coached by the scammers about how to answer questions from his banks. In those circumstances, he thought it was unlikely that intervention from Wise would have been effective. Mr H did not accept the Investigator’s assessment. He reiterated that Wise should have intervened to ask him questions about the payment. Intervention was particularly necessary given that he was vulnerable. He said the intervention from Mr H’s other bank was general and limited and did not mean Wise shouldn’t also have intervened. He says he answered several questions honestly and he was under significant pressure and confusion. With appropriate and meaningful questions, it is more likely than not that he would have reconsidered the payment and delayed it long enough for the scam to be exposed. Mr H asked for his complaint to be passed to an ombudsman for a decision. 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’m not upholding Mr H’s complaint. While I understand this will come as a disappointment to Mr H and I am conscious of the impact this cruel and distressing scam has had on him, I’m not persuaded that I can fairly conclude that Wise is responsible for his losses. I say this because I don’t consider further intervention would have uncovered the scam. I’ll explain why. In broad terms, the starting position is that Wise is expected to process payments that a customer authorises it to make, in accordance with the accounts terms and conditions and with the Payment Services Regulations (PSRs). It isn’t in dispute that Mr H authorised this payment. Wise had an obligation to process the payment, but that isn’t the end of the story. I’ve taken into account the regulator’s rules and guidance; relevant codes of practice, along with what I consider to have been good industry practice at the time. Having done so, I consider Wise should have fairly and reasonably been on the lookout for the possibility of Authorised Push Payments scams (amongst other things) at the time, and intervened if there were clear indications its customer might be at risk. Wise has a difficult balance to strike in how it configures its systems to detect unusual activity that might indicate its customers are a higher risk of fraud. It would not be reasonable or possible for Wise to intervene in every transaction it processes. I would expect intervention to be proportionate to the circumstances of the transaction.

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In Mr H’s case, I consider Wise should have intervened in this transaction and should have asked him probing questions about the payment. I say this mainly due to the size of the payment. I accept that there was no account history with which to judge Mr H’s usual patterns of payments. I also accept the payment was not inconsistent with the account opening purpose Mr H gave when opening the account. He had told Wise he would use the account to move his savings, so using the account to transfer a one-off large sum wasn’t inconsistent with that. While Wise says the payment was made to another of Mr H’s accounts, by July 2025, it would have been aware of the prevalence of scams involving transactions between accounts controlled by the same customer, so I do not consider the fact the payments were being made to another account in Mr H’s name should have satisfied Wise that there was no risk here. In view of the size of the payment, I consider intervention by messaging through a banking application, would have been a suitable form of intervention. Wise should have asked Mr H probing questions to establish whether he was at risk of financial harm from fraud. However, like the Investigator, I’m not persuaded that such intervention would have uncovered the scam and prevented Mr H’s losses. When Mr H’s bank called him on 17 July 2025 it asked him a number of questions about the payment. He initially told his bank the payment was to send money to different accounts abroad but when asked for further information, he told his bank that he was making the payment to do some trading. His bank established that Mr H was making the payment to a platform that traded commodities, foreign currency and stocks. He gave his bank some inaccurate information, for example he said he had not been asked to download any remote access software and he had not been asked to mislead the bank. But during the call, Mr H said he was now a bit nervous about the payment and his bank asked whether he would like to make further checks. It suggested carrying out some more research and checks before making the payment and Mr H said he would think it over and call back. In a second call with his bank later that same day, he said he’d made some checks and now he didn’t want to go ahead. He said he didn’t know whether this trading platform was legitimate, he asked his bank whether it had heard of the platform and his bank said it hadn’t. He said he just didn’t know what was genuine and what wasn’t and it all seemed a bit too good to be true, so he was not going to proceed. On the one hand, Mr H didn’t provide his bank with accurate information, which made it harder for his bank to determine whether he was being scammed. On the other, he did answer some questions accurately and he was not so completely taken in by the scammers that he simply decided to go ahead. He was clearly aware of the possibility this might be a scam. He seems to have considered it, weighed it up and decided not to proceed at that point. However, Mr H messaged the scammers and said he had made a ‘mistake’ and had told his bank the payment was for trading and the bank wouldn’t release the money. I conclude from this that Mr H had been told to give his bank a different payment purpose, otherwise there would be no mistake in telling his bank the real purpose of the payment. Mr H confirmed to us that he had been told by the scammers to mislead his bank because banks ‘did not like investments’. The messages Mr H exchanged with the scammers indicate that he spoke to the scammers by telephone. The messages are quite aggressive in tone and Mr H says the scammers were aggressive but also persuasive when talking to him and they reassured him that everything was in order. On 18 July 2025, Mr H attempted to make another payment from his bank to the scammers.

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In a call on 18 July 2025, his bank asked for some further detail about the payment. He said he was sending it to his account with Wise to put in multiple accounts abroad in different currencies. He was asked if anyone guided him on how to answer the bank’s questions. He said no, but he had been guided, for example the payment purpose he gave appears to have been the same answer he had been told to provide in his original call with his bank. He was also asked whether he’d been asked to download anything to share screens and he said no, but again, he had been asked to do that and he had downloaded remote access software. His bank was satisfied with his answers and made the payment. While intervention from Wise might have involved different questions and might have produced different results, I consider the evidence from the calls between Mr H and his other bank is likely to be the best evidence about how Mr H might have responded if Wise had intervened. It is clear Mr H was told to mislead his banks about the purpose of the payments, about having downloaded remote access software and about receiving guidance about how to answer the bank’s questions. It’s also clear that he followed this advice and tried to give inaccurate answers in the first call on 17 July and in the call on 18 July. Mr H clearly had some doubts, for example he said that the investment seemed too good to be true and he couldn’t determine whether the platform was legitimate. Mr H’s bank was able to raise enough doubt in Mr H’s mind for him to cancel one of the payments, which suggests an intervention from Wise might have worked. It’s possible that if Wise had intervened and had intervened with more probing questions than his bank, or had followed-up some of the information Mr H gave, the scam might have been uncovered. For example, he wasn’t asked how he had heard about the investment, which might have been an obvious line of enquiry. He was encouraged to check that the payment was going to who he thought it should be going to, but he wasn’t told to check the FCA website to see if there were any warnings about this platform. He was told he should carry out further due diligence, but it wasn’t really explained what that meant. He wasn’t warned about fake investment and trading websites. It’s possible that if Wise had intervened, it would have succeeded where his bank failed. But, ultimately, the intervention from Mr H’s bank wasn’t successful because Mr H contacted the scammers and was persuaded to make a payment the next day and to provide misleading information to his bank when making that payment. He did this despite the doubts he had and despite the intervention from his bank. He told us the scammer was very persuasive and reassured him that everything was okay and on that basis he decided to go ahead. On balance, while this is a finely balanced case, I’m not persuaded that if Wise had intervened and asked Mr H probing questions, that he would have answered them accurately or that he would have given Wise sufficient reason to think that the payments were being made as part of a scam. My final decision I don’t uphold Mr H’s complaint. Under the rules of the Financial Ombudsman Service, I’m required to ask Mr H to accept or reject my decision before 3 April 2026. Greg Barham Ombudsman

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