DRN-6296326

The complaint Mrs H complains that NATIONAL WESTMINSTER BANK PUBLIC LIMITED COMPANY won’t refund money she lost when she was a victim of a scam. Mrs H is represented by a firm I’ll refer to as ‘R’. What happened The background to this complaint is well known to both parties and so I’ll only refer to some key events here. Mrs H fell victim to a crypto investment scam in 2021. R complained to NatWest, on Mrs H’s behalf in May 2025 – saying they failed to protect her from the scam. R wanted NatWest to refund Mrs H in full and pay 8% simple interest. NatWest rejected the complaint and it was referred to the Financial Ombudsman. Our Investigator didn’t think NatWest were responsible for Mrs H’s loss. R disagreed. And so, the matter was passed to me to decide. I wrote to R and explained I’d come to the same outcome as our Investigator and for similar reasons. I said: • “Mrs H made about 30 payments from her NatWest account as part of an investment scam between 11 February and 3 June 2021. The payments went to the scam trading platform via a legitimate crypto provider (C). They totaled just over £9,000. • I’m not persuaded the payments being disputed here would’ve presented a heightened risk of financial harm that warranted NatWest to carry out additional checks before processing the payments. This is because: o There is a balance for NatWest to find between allowing customers to be able to use their account and questioning transactions to confirm they’re legitimate. o Although there is a known fraud risk associated with crypto, this wasn’t as well-known or prevalent as it has since become. And the vast majority of payments related to crypto are made for legitimate purposes. o The payments were relatively low in value – with the highest being £1,165. And even when there were several payments made on a single day, the highest combined value was only £1,750. o The payments were spread across nearly four months. And so, they weren’t made in rapid succession. Nor did they incrementally increase in value. So, they didn’t present a payment pattern that I consider was indicative of an investment scam. • Mrs H has explained one payment was blocked by NatWest, which required her to visit one of their branches and speak to their fraud team over the telephone. And that the branch staff said they didn’t know anything about crypto, and the fraud team simply removed the block without providing scam warnings – but, instead, focused on whether her ID had been verified and the trading platform account/website had been viewed.

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• Unfortunately, due to the time that has since passed, NatWest cannot confirm whether any of the payments flagged for checks. Because of this, I can’t be certain what was discussed at the time – including whether the checks were proportionate to the risk identified by NatWest (or not). • Consequently, it’s difficult for me to reasonably conclude that NatWest missed an opportunity to uncover the scam. That said, from what Mrs H has said, it seems they did take at least some steps to protect her from the risk of financial harm – by ensuring she had authorised the payment(s) and that they were, seemingly, going to an account in her own. • As I’ve said I wouldn’t reasonably have expected NatWest to have carried out additional checks before processing the payments. And so, if Mrs H’s description of what happened is accurate then it is still more than I would’ve expected in the circumstances. • It’s also worth noting that, at the time these payments were made, the common features of crypto scams would’ve been less known. And so, while multi-stage fraud is now a more obvious ‘red flag’ that banks should be on the lookout for, this wouldn’t necessarily have been the focus of their fraud prevention checks at that time. Instead, it would’ve likely been on ensuring their customers were satisfied they were dealing with a legitimate firm, they’d carried out their research and that they were aware of the risks in dealing with crypto due to its unregulated nature. • As I’ve said, I can’t be sure whether this was included as part of the intervention Mrs H says NatWest carried out. But from my own online search, I’ve been unable to find anything that suggests the firm Mrs H was dealing with was reported as being a scam at the time. So, even if NatWest had asked Mrs H to carry out further checks before making the payment(s), I can’t reasonably conclude this would’ve uncovered the scam or deterred her from making it. I know Mrs H is the innocent victim of a scam here. But it would only be fair for me to direct NatWest to refund her loss if I thought they were responsible. Ultimately, as I’ve said, I don’t think the payments being disputed warranted additional checks being carried out before NatWest processed them. And even if there was an intervention (which NatWest has no record of), this would’ve been more than I would’ve reasonably expected in the circumstances. Nor am I able to fairly conclude that NatWest missed an opportunity to uncover the scam either. It follows that I don’t think NatWest are responsible for Mrs H’s loss. I therefore think NatWest have acted fairly and so I’m not going to tell them to do anything further.” Mrs H remained dissatisfied and provided further information for my consideration. I’ve therefore proceeded to make a final decision on her complaint. 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. I’m sorry Mrs H has been the victim of a scam, and I don’t underestimate the impact this has had. I understand why Mrs H would do everything she can to try and recover her loss. But having given Mrs H’s complaint further thought, I’m not persuaded to depart from the above. I’ll explain why. I know Mrs H disagrees, but I don’t think the payments to C were unusual or suspicious enough whereby I consider it warranted NatWest to carry out additional checks before processing them. When considering this, I’ve kept in mind that banks process high volumes

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of transactions each day – and that it’s not practical for banks to carry out additional checks before processing every payment. I accept that these payments were more than Mrs H typically spent on her account – with most prior transactions less than £100. But it’s also common for customers to make higher value payments on their account at times. And the payments being disputed here, while not an insignificant amount, were relatively low value – particularly in contrast to what NatWest process. And although, at times, several payments were made on the same day, the combined value didn’t become what I consider would’ve been significant to have given NatWest reason to be concerned. Nor, as I’ve said, did the transactions incrementally increase in value. And as they were spread out over several months, I don’t think there was a clear payment pattern that was indicative of an investment scam which NatWest ought reasonably to have identified. Ultimately, I don’t think the payment activity presented a heightened risk of financial harm from fraud. Instead, I think it would’ve appeared as legitimate account usage. Because of this, I wouldn’t have expected NatWest to have carried out additional checks before processing them. I understand Mrs H has set out in some detail her recollection of a block placed on her account, that she had to visit a NatWest branch and spoke to their fraud team to discuss one of the payments she was trying to make. While I’ve no reason to disbelieve Mrs H, due to the passage of time, NatWest do not – unfortunately – have a record of this conversation. I understand Mrs H will be frustrated by this as she feels the telephone conversation would support her claim. But in the absence of this, I cannot be sure what fraud checks were carried out at the time. Consequently, I can’t reasonably conclude that NatWest failed to undertake a proportionate intervention at the time of the payment(s). In any event, and as I previously explained, I think it’s important to note that even if NatWest did intervene as Mrs H has stated, any checks they carried out would’ve been more than I would’ve reasonably expected. And due to absence of evidence available from the time the payments were made, there’s nothing to suggest NatWest were put on notice – or ought reasonably to have become aware – that Mrs H was making them to a scam. It follows that I can’t fairly conclude that NatWest are responsible for the loss Mrs H suffered. I’ve also considered whether, on being alerted to the scam, NatWest could reasonably have done anything to recover Mrs H’s losses, but I don’t think they could. This is because NatWest could’ve only sought to recover the funds from C, and we know it had already been forwarded on as part of the scam. But even if funds had remained, they would’ve remained accessible to Mrs H. And in respect of the debit card payments, there wasn’t any reasonable prospects of success via a chargeback claim (as the service had been provided by C). On a final note, I’m aware Mrs H has referred to the payments to C being made via a payment processor (‘CB’). And so, as it could’ve been going another person’s account, Mrs H has suggested account restrictions would’ve been warranted due to NatWest’s money laundering obligations. But as there hasn’t been suggestion these payments were made for money laundering purposes, I can’t say NatWest failed to act appropriately in this regard either. I realise Mrs H will be disappointed by this outcome. I sympathise greatly. But for the reasons I’ve explained, I don’t think NatWest are responsible for her loss. I therefore think NatWest have acted fairly and so I’m not going to tell them to do anything further.

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My final decision My final decision is that I do not uphold this complaint. Under the rules of the Financial Ombudsman Service, I’m required to ask Mrs H to accept or reject my decision before 25 May 2026. Daniel O'Dell Ombudsman

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