DRN-6256571

The complaint Miss C complains MONZO BANK LIMITED (“Monzo”) is holding her liable for payments which she says she didn’t authorise. What happened The details of this complaint are well known to both parties. So what I’ve set out below is only a summary of the key events. In early November 2025, Miss C reported to Monzo that payments had been taken from her account in October 2025 which she didn’t recognise. This comprised of an ATM transaction, which Miss C later confirmed had been included in error, and several payments to a merchant I’ll refer to as “X”. A few weeks later, she disputed another payment from that time to a different merchant, “L”. I’ve set out the disputed payments below: Date and time Merchant paid Payment type Amount 05/10/2025 11:31 X Debit card - 3DS authenticated £16.74 09/10/2025 11:40 L Debit card - chip and PIN £170 09/10/2025 20:52 X Debit card - 3DS authenticated £17.49 21/10/2025 18:36 X Debit card - 3DS authenticated £8.39 Total £212.62 Miss C told Monzo she believed an abusive ex-partner, who had been staying with her at the relevant time, made these payments without her authorisation. Monzo concluded she was liable, and gave notice it would be closing her account. When Miss C complained about this decision, Monzo awarded her £50 compensation for its service but didn’t otherwise change its position. So Miss C referred the matter to our service. Our Investigator didn’t uphold Miss C’s complaint. In summary, looking at how the payments had been made and the account had been managed, she didn’t consider it likely that an unauthorised person could have got the level of information and access needed to make the payments. She also thought Monzo had acted fairly and in line with the account terms when closing the account, and that it didn’t need to pay further compensation. Miss C has appealed the investigator’s outcome. She maintains she didn’t make the payments, suggesting her ex-partner could have observed her security details and accessed her belongings without her knowledge or consent. Miss C has also explained she was in vulnerable circumstances at the time, and also suggests Monzo should have intervened on the disputed account activity. 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.

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Having done so, I’ve decided not to uphold it. I appreciate this will be disappointing for Miss C, particularly given what she has explained about her circumstances at the time. But I don’t think Monzo has treated her unfairly by not refunding these payments or closing her account. I’ll explain why. Is it fair for Monzo to hold Miss C liable for the payments? Miss C asserts that these payments were made without her authority; she has explained she suspects they were made by her ex-partner, who was staying with her at the time of the payments – and who she has explained was abusive to her. Monzo ultimately concluded Miss C had authorised the payments. In situations like this, I can’t be sure about what happened. I must therefore use the available information to decide what I think is more likely to have happened. In line with the Payment Services Regulations 2017, firms are expected to process authorised payment instructions without undue delay. So, the starting position is generally that Miss C would be liable for payments she authorised – but Monzo would be liable for payments taken without her authority. I’ve looked at how these payments were made. The payments to X were all 3DS authenticated. So for an unauthorised person to have made them, they would have needed to know Miss C’s card number, expiry date and CCV. They would also have needed access to her phone to complete the 3DS approval screen within Miss C’s Monzo app – requiring knowledge of security details, such as the passcodes to access the phone and app. The payments to X were also made over the span of a few weeks, on three different days. So an unauthorised person would have needed to have got access to and used Miss C’s phone, and then returned it, on several different occasions without her knowing. The other disputed payment was authenticated via chip and PIN. So, that meant an unauthorised person would have needed to have used and returned Miss C’s physical card without her realising, as well as knowing her PIN. They would have needed to do all this in amongst getting the access and information needed to make the payments to X – and also avoiding detection despite Miss C accessing and using her account during this period. From what Miss C has told us, she didn’t notice her card or phone being lost, even temporarily, during this time. She has also confirmed that she didn’t knowingly share her security details, such as her card PIN. In considering what is more likely to have happened, it’s therefore difficult to see how an unauthorised person could have got the level of access and information needed to make these payments without Miss C’s knowledge. I have thought about what Miss C has explained about her ex-partner, including how it’s possible he could have got access to her phone and belongings, and may have observed her entering her PIN. I accept that is possible, particularly given what Miss C has explained about the nature of the relationship being abusive and controlling. So, I’ve carefully considered this possibility. However, I still don’t think it’s the more likely explanation here. The scenario would still have required Miss C’s ex-partner to have accessed her card and phone without her noticing. Additionally, all of the payments were preceded by credits into the account shortly beforehand – the first from a third party, the remainer from Miss C’s own accounts.

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Miss C has confirmed that she accessed her Monzo mobile banking during the period of these payments, and that it was her who paid in credits from her other account(s). This includes topping up her account after the first transfer to fund further, undisputed spending. I have taken on board what Miss C has explained about the vulnerable circumstances she was in and the impact these may have had on what happened here. However, I can’t overlook that the way in which the account was being used overall – which suggests Miss C was likely aware of the spending, contrary to her assertion that she didn’t know or agree to any of these payments at the time. Having carefully weighed everything up, I think it’s fair for Monzo to treat these payments as being authorised by Miss C. To be clear, that would include scenarios where she allowed someone else to use her card/account – even if they then spent in a way that perhaps went beyond what she was expecting. As explained above, that means the starting position is that she is liable for the payments. More widely, I have considered if Monzo ought to have identified the payments as carrying a heightened fraud risk – and so should have taken action which would likely have prevented the loss here. However, given the spread of the payments; their (relatively) low value and how they appeared in amongst Miss C’s undisputed account activity, I think it was reasonable for Monzo to simply process them without completing further checks. Overall, I don’t think it would be fair to expect Monzo to refund Miss C for these payments. Was the account closure handled fairly? I appreciate this decision caused Miss C some inconvenience and upset. However, in looking at what the account terms say, they do make clear that the account can be closed by giving at least two months’ notice – which Monzo did here. This allowed Miss C time to make other arrangements, and it also appears she held other accounts which I think helped minimise the impact. From what I’ve seen, I don’t think Monzo acted unreasonably or made an error when deciding to close Miss C’s account (or how it handled this). Overall, I’ve thought carefully about what happened here – particularly given what Miss C has explained about the difficult circumstances she was in and what bearing they may have had. Having done so, I don’t think it would be fair to direct Monzo to refund Miss C for the payments she is disputing - or to otherwise compensate her in relation to this complaint. Should Monzo pay further compensation? As mentioned above, Monzo paid Miss C £50 compensation as she was unhappy with its service while looking into her claim – particularly around having to reiterate herself. I’ve therefore considered whether this award fairly reflects any unavoidable distress and inconvenience caused by any service failings by Monzo. I do appreciate that this overall situation has been stressful and unpleasant for Miss C, and empathise with her frustrations over how the claim was handled. However, I’m also conscious Monzo needed to ensure it fully understood the basis of Miss C’s dispute to ensure it reached a fair outcome. Overall, I consider its level of questioning and investigation reasonable – and I don’t think it needs to pay further compensation. My final decision For the reasons given above, my final decision is that I do not uphold this complaint. Under the rules of the Financial Ombudsman Service, I’m required to ask Miss C to accept

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or reject my decision before 26 May 2026. Rachel Loughlin Ombudsman

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