DRN-6261818

The complaint Ms S is unhappy that Revolut Ltd won’t refund payments she made as part of a scam. She has brought her complaint with the help of professional representatives, but for simplicity I’ve referred to her actions throughout the decision. What happened Ms S received a phone call from someone offering a job opportunity, who said they’d seen her CV on a recruitment website. The work was task based, and involved rating and simulating the purchasing of items from various merchants. As that would increase the algorithm for the products, commission would be paid by the retailers in return. Ms S was told to open up a wallet with a cryptocurrency provider, and make deposits onto the job platform in order to unlock the tasks. It was explained that after completing a set of tasks she would be able to withdraw the money paid to simulate the purchase as well as the commission earned. So in early January 2025 Ms S sent payments from her bank account to her Revolut account, and onto a cryptocurrency exchange I’ll call “C”. After converting her funds to cryptocurrency at C, it was then withdrawn to the wallet address for the job platform. The cost of the tasks started off small and so the amounts initially sent to C were also lower in value. Ms S even withdrew some earnings back to her Revolut account. But eventually higher deposits were required in order to continue with the work – and on 6 January 2026 Ms S attempted to transfer more than £3,000 to her wallet at C. Revolut asked some automated questions in app and was told the payment was for an investment, so it showed some warnings highlighting common features of investment scams. Before allowing the payment Revolut spoke with Ms S over the phone, and she told the agent she was trying out investing on her own having learned from a family member for the past year. Ms S also said she was keeping her money in C’s cash wallet to stop her from using it for shopping, and was investing small amounts cautiously (buying and selling cryptocurrency within the platform) after seeing some initial success. She confirmed that the funds remained at C and she was comfortable with what she doing following some research. Ms S also told Revolut that she had experience of how to spot scams through her work. Revolut released the transfer after the call, and over the next two days Ms S was allowed to make additional payments to C totalling around £7,750. No further fraud checks were completed. Ms S says she realised she’d been scammed when a withdrawal was blocked, which resulted in all contact being cut and the removal of her access to the platform. A complaint was raised with Revolut that said the account activity was out of character and should have prompted a strong intervention. Had that happened Ms S believed the scam would have been uncovered. Revolut asked for evidence to support Ms S’s claim, like the communication with the scammers, but says it didn’t receive a reply. So it issued a final response that said it wasn’t responsible for the loss. Ms S wasn’t happy with the outcome and so referred the complaint to the Financial Ombudsman Service for review. One of our investigators considered everything and didn’t recommend the complaint was

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upheld. In her view, Revolut had intervened appropriately but Ms S’s answers to the questions hadn’t highlighted anything concerning. The investigator acknowledged Ms S has been given a cover story by the scammers, but thought it was reasonable for Revolut to have been reassured she wasn’t at risk following its checks. Ms S didn’t agree, and argued that Revolut’s questioning didn’t go far enough. She asked for the matter to be reconsidered by an ombudsman, so the complaint was passed to me for a final 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 Ms S’s complaint. I appreciate that will come as a great disappointment to Ms S, who I know feels strongly that Revolut should have done more. I was also saddened to hear that this happened at a time when she was already struggling with her mental health. Ms S certainly has my sympathies for what she’s been through. The disputed payments went to an account elsewhere at a cryptocurrency provider that was under Ms S’s control, meaning they aren’t covered by the mandatory fraud reimbursement scheme introduced by the Payment Systems Regulator. So for me conclude that Revolut should provide a refund I would need to be satisfied that it was at fault in some way for the loss. That involves looking at whether it ought to have done more in relation to its fraud prevention responsibilities. I’ve decided that isn’t the case here, and I’ve explained why below. In broad terms, the starting position in law is that an Electronic Money Institution like Revolut is expected to process payments and withdrawals that its customer authorises it to make, in accordance with the terms and conditions of the account and the Payment Services Regulations (PSRs). Ms S ‘authorised’ the transactions in question (she made them), albeit under the belief they were for a legitimate job opportunity. So the starting position is that Revolut was under an obligation to process the payments – but that isn’t the end of the story, as far as its responsibility in the matter goes. I’ve also 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. I’ve also applied Revolut’s terms for the account, which say it can delay payments and make enquiries in order to meet its regulatory requirements. Those together mean I consider Revolut should fairly and reasonably have been on the lookout for the possibility of fraud at the time, and intervened if there were clear indications its customer might be at risk. Revolut has a difficult balance to strike in how it configures its systems. It needs to detect unusual activity, or activity that might otherwise indicate a higher than usual risk of fraud, whilst not unduly hindering legitimate transactions. There are many millions of payments made each day, and it would not be possible or reasonable to expect firms to check each one. In situations where firms do (or ought to) carry out checks, I would expect that intervention to be a reflection of the risks involved. Revolut spoke to Ms S over the phone prior to allowing the largest of the disputed transactions. So the first question for me to decide is whether that intervention was proportionate in the circumstances. The call with Ms S was 20 minutes long and Revolut asked a lot of questions about the purpose of the large payment, as well as the recent change in activity on the account. Revolut identified she had made several smaller transfers to the same cryptocurrency provider in the preceding days, which were explained as testing out that platform. Revolut

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could see Ms S had been able to withdraw from C too, and was told there weren’t any third parties involved – nor were the funds being sent on anywhere from there. Ms S explained she’d done her research and was keeping her money at C to avoid her spending it. Revolut also warned Ms S that if she was being told to hide what she was doing then she was dealing with scammers. Revolut needed to be alive to the fact scammers provide their victims with cover stories, but there weren’t any inconsistencies that might indicate coaching or otherwise concerning aspects in what it was told during the conversation. The fact Ms S was keeping her money at C to avoid spending it was believable too, as there are usually fees for withdrawing from those types of wallets, which would act as a deterrent. Overall, I think the explanation Revolut was given was plausible in the circumstances and would have provided reassurance Ms S wasn’t likely at risk. It wasn’t on notice she was vulnerable either. So I find it was reasonable that Revolut treated the transactions up to that point as legitimate and allowed the larger payment. However, as things continued to escalate on the account, I think Revolut ought to have intervened again the following day – before allowing the third payment (£2,550). Money had continued to be sent to C across multiple transactions in the intervening period, and the amounts were starting to increase again – with that £2,550 transaction bringing the total going to cryptocurrency since the last intervention to around £7,750. Revolut didn’t intervene again as it should have, so we can’t know for sure what would have happened. I appreciate that means I’m now having to speculate on what I think would most likely have happened, and that’ll inevitably feel unsatisfactory. But, having considered the circumstances, I still don’t think Revolut would have likely uncovered what was really happening if it had spoken to Ms S again at that later point. I haven’t got any evidence of the communication between Ms S and the scammers, so I can’t see the motivation for misleading Revolut discussed, or the extent to which she was being coached on what to say. I also haven’t seen whether any doubts had been expressed by Ms S prior to this point to help me assess how committed to the cover story she was. I appreciate that isn’t her fault, and that she’s tried to recover the chats, but it still remains the case. So in the absence of that information I’m concluding Ms S would have likely continued with the cover story of sending money to C to stop her from spending it, and also said she was trading some of it cautiously having trained with a family member for a year on what to do (with no third party involvement, or the funds being moved on from C). Things were starting to escalate on the account, but that story would still have been plausible at the point the second intervention should have happened. The smaller payments made to C after the call were following payments in from other third parties, so that could easily have been explained as people paying her back and her moving the money to the cash wallet for safe keeping. Some money was also taken out of C and transferred out of the Revolut account, but again I think that could have been explained (as covering bills for instance). Ms S was moving money through her Revolut account, but that wasn’t overly unusual for her, and she’d addressed that during the previous call. So, while the activity overall might have looked suspicious at first glance, on balance I find that Ms S would likely have been able to reassure Revolut she wasn’t being scammed if it spoke to her again. That means I don’t consider Revolut ought to have been able to prevent the loss here. I’ve thought about whether Revolut should have done more once the scam was reported, and I haven’t found there were any failings in that regard. The payments went to an account in Ms S’s name, with the funds converted and sent on from there – so there wouldn’t have been anything at C for Revolut to recover that Ms couldn’t have recovered herself. There were no service issues either that I consider would warrant compensation.

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Having considered everything, and whilst I recognise that Ms S has sadly lost this money, I don’t think Revolut could reasonably have been expected to prevent that loss. I also don’t think it missed signs of Ms S’s vulnerability. So, I’m not directing Revolut to refund the disputed transactions. My final decision I’ve decided not to uphold Ms S’s complaint about Revolut Ltd. Under the rules of the Financial Ombudsman Service, I’m required to ask Ms S to accept or reject my decision before 25 May 2026. Ryan Miles Ombudsman

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