Revolut Ltd · DRN-6127602

The complaint Mr M complains that Revolut Ltd will not refund money he lost when he was a victim of an investment scam. Mr M is professionally represented, however for ease, I’ll refer to Mr M throughout my decision. What happened The background to this complaint is well known to both parties and so I’ll only refer to some key events here. Mr M has explained that he fell victim to an investment scam in 2022, whereby he came across a firm, which I’ll refer to as ‘X’, advertised on social media referring to an investment opportunity. As part of this scam, Mr M was convinced to download a trading platform for X and he made an initial payment of £204.41 from his other banking provider, which I will refer to as ‘S’. Mr M also sent funds from S, including from a business account he held at S to Revolut, before making numerous payments to a genuine crypto exchange provider from Revolut, which X helped him set up, that was subsequently lost to the scam. Mr M also sent funds from another banking provider, which I will refer to as ‘O’. In total Mr M made twenty- one (21) transactions to X from his Revolut account in euros totalling around £350,000, over a seven-month period between 23 June and 7 December 2022. He also received returns from X of just under £18,000 between July and August 2022. Mr M has raised separate complaints against S and O, which I will address individually. Mr M said he realised he’d been scammed when he confided in a friend in December 2022 about his investment with X. After his friend carried out some research, he found out that the Financial Conduct Authority (FCA) had issued a warning against dealing with X on 21 November 2022, as it was likely they were providing financial services and products without FCA authorisation, and the warning said, you should avoid dealing with this firm and beware of potential scams. Mr M raised a complaint with Revolut in June 2025, which they didn’t uphold, so the matter was referred to our service. Our Investigator also didn’t uphold the complaint. He said, Revolut, S and O, did intervene on some of the payments Mr M made and provided him with warnings. However, even if further interventions were carried out, he didn’t think it would’ve uncovered the scam or prevented Mr M from sending the funds, due to the influence of X and the coaching and guidance he had received, so he didn’t think Revolut needed to do anything else. Mr M didn’t agree and said Revolut should have done more to protect him from the investment scam he fell victim to. He said a proportionate intervention from Revolut would’ve resulted in the scam being uncovered and his loss being prevented. As no agreement could be reached, Mr M’s complaint has been passed to me to decide.

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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 Mr M has been the victim of a scam, and I don’t underestimate the impact this has had on him. But while I’m sympathetic to Mr M’s circumstances, I must consider whether Revolut is responsible for the loss he has suffered. I know this won’t be the outcome Mr M is hoping for, but for similar reasons as our Investigator, I don’t think they are. And so, I don’t think Revolut has acted unfairly by not refunding the payments. I’ll explain why. In broad terms, the starting position in law is that an electronic money institution (EMI), is expected to process payments that their customer authorises them to make. It isn’t disputed that Mr M knowingly made the payments from his account and so, I’m satisfied he authorised them. Therefore, under the Payment Services Regulations 2017 and the terms of his account, Revolut are expected to process Mr M’s payments, and he is presumed liable for the loss in the first instance. However, taking into account the regulatory rules and guidance, relevant codes of practice and good industry practice, there are circumstances where it might be appropriate for Revolut to take additional steps or make additional checks before processing a payment to help protect customers from the possibility of financial harm from fraud. When considering this, I’ve kept in mind that EMIs process high volumes of transactions each day. And that there is a balance for Revolut to find between allowing customers to be able to use their account and questioning transactions to confirm they’re legitimate – as it wouldn’t be practical for EMIs to carry out additional checks before processing every payment. I need to decide if Revolut acted fairly and reasonably in their dealings with Mr M when he made the payments. Specifically, whether they should’ve done more than they did before processing them – and if they had, would that have made a difference. But for me to find it fair and reasonable that Revolut should refund Mr M requires more than a finding that Revolut ought to have intervened or done more, but crucially I’d need to find that but for this failure the subsequent loss would’ve been avoided. That latter element concerns causation. A proportionate intervention will not always result in the prevention of a payment. And if I find it more likely than not that such a proportionate intervention by Revolut wouldn’t have revealed the payments were part of a fraud or scam, then I couldn’t fairly hold them liable for not having prevented them from being made. Here, Revolut have said Mr M was provided with the following warning when he attempted to make the first payment of 1 euro (86p) on 23 June 2022, from his Revolut account to a new beneficiary - that being the crypto exchange account Mr M opened under the guidance of X.

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“Do you know and trust the payee? If you’re unsure, don’t pay them, as we may not be able to help you get your money back. Remember, fraudsters can impersonate others, and we will never ask you to make a payment.” Mr M confirmed he understood the potential risks and wanted to proceed with the transaction. Revolut have said no further interventions were made aside from the new beneficiary warning. I agree with the Investigator that Revolut should have provided further interventions on some of the later payments Mr M made, due to the high value of the payments and other factors that could have indicated Mr M might be falling victim to a scam. However, in my opinion, I’m not satisfied any intervention would have prevented Mr M from making the payments or uncovering the scam, due to the influence and guidance of X on Mr M, which I will explain in more detail later. S’s intervention I’ve also considered, Mr M’s interactions with S, which included a telephone call that took place on 23 June 2023, after he attempted a payment of £5,000 from S to Revolut which was blocked by S for further checks. On the call, Mr M told S the following: o He was making the payment to a new account he’d opened with Revolut in his own name. o He confirmed he made a smaller payment to the same account earlier in the day to check if the new account worked, which it did. o He asked S if the payment was blocked due to the value, which the advisor denied, and if he will have similar issues going forward, which the advisor said, it should be fine as the account details match. Based on the conversation between Mr M and S, he was provided with safe account scam warnings and the payment was approved. S have confirmed no further interventions took place as Mr M made further payments from S to R to fund the scam. O’s interventions Mr M was also provided with the following new payee warning from O on 8 July 2022, when he made a payment of £100 to his Revolut account. “New payee warning Could this payment be to someone trying to scam you? If you have any doubts (for example you don’t personally know the recipient, get some advice. Bear in mind that once you make a payment, it’s almost impossible for us to get the money back.” Mr M confirmed he understood the risks involved and decided to proceed with the payment. O then showed Mr M the following warning: “Could someone be trying to scam you? Stop if:

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• You were told your account is at risk, to make an unexpected payment, or to take out a loan. • The offer sounds too good to be true. • You haven’t double-checked who you’re paying. • You were told to ignore warnings like this. You may lose money if this is a scam. If you’re at all unsure, stop and get advice. We’ll never call you out of the blue We’ll always let you know in advance by email or by arranging it in the app chat first” Mr M confirmed he had read and understood the above warnings and he wanted to continue with the payment, which he did. Mr M also asked O to increase his limit on three occasions, which required him to provide identification, which he did, as well as a reason for the limit increase. In response, Mr M said the following on 26 July 2022; “The money is being sent to Revolut personal account as I’ve already mentioned earlier in this chat and also included as a reference in both selfies. Maybe you need to take another look at my selfies”. O also provided the following warning to Mr M when he requested the limit increases: “Finally, in an effort to help protect you against fraud, please note: a bank will never ask you to increase your limits and if they have, it may be a scam. If someone has asked you to increase your limits, including someone claiming to be from O or another bank, please don’t continue and let our team know instead so we can help you with next steps.” O didn’t intervene on any further payments Mr M made to his Revolut account, which overall totalled just over £110,000. Scam chat review I will not set out the specifics of the scam chat Mr M had with X here, as he is already familiar with it. But where the evidence is incomplete, inconclusive, or contradictory, I must make my decision on the balance of probabilities – that is, what I consider is more likely than not to have happened in the light of the available evidence and the wider surrounding circumstances. In this situation it’s clear Mr M has various telephone conversations with X during the scam period, which unfortunately, aren’t available for us to review. However, I think it’s clear from the scam chat, Mr M had built up a strong relationship with X before he made the first payment to X on 23 June 2022 from S. This is evident from the scam chat we’ve been provided, when X told Mr M on 22 June 2022, to download and open an account with a crypto exchange provider, as well as an account with Revolut following a phone call conversation, which Mr M did on the same day. When Mr M was unsure about how to do anything X had asked him to do, Mr M would ask X to call him to explain the process which happened on several occasions. On 23 June 2022, Mr M told X, S had blocked his account as the payment needs to undergo a further review. X asked if he had another account, or a different way to move money around. Mr M mentioned he didn’t have another bank account, but he suggested himself that he might transfer both his accounts over this issue. On 27 June 2022, X said the following: “You have to move bank!” after Mr M said his account with S had been blocked again, after he attempted a £10,000 payment to his

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Revolut account. Mr M replied with: “That’s my plan”. And the next day, on 28 June 2022, Mr M confirmed to X he had managed to switch both his current and business account from S to O, which is a clear indication that Mr M was circumventing any friction or interventions he received from his banks to allow him to continue making the payments to X. On 17 August 2022, following a call between X and Mr M, when the conversation moves back online, Mr M talks about his properties and the value of his property in London, which he said he’s arranged for a mortgage valuation with an estate agent to sell the property. This again is a strong indication of the influence and guidance of X on Mr M. He also mentioned to X on 7 September 2022, that he will need to provide further details to the provider about a larger loan he has applied for. Although, Mr M didn’t go ahead with the loan and instead decided to sell his house, he was willing to make up a cover story to convince the lender why he needed the large loan, when on 24 October 2022, Mr M said the following to X: “Whichever option we use we will need to provide details of the works that you intend to carry out to the house and these would need to be non-structural, not require full planning and the house will need to remain habitable throughout the works. I’m seeing if my builder can make me up a quotation. I will struggle to substantiate £200k. Will see what I can do”. Summary The above information is a clear indication of the lengths Mr M was willing to go to, to ensure his payments to X went through without any friction. The scam chats we have available include Mr M willing to sell his house; discussing providing falsified quotations to get a large loan approved, and moving his bank accounts, when payments were being blocked for further questions to avoid any delays in making the payments to X. As a result, even though I do think Revolut should have intervened on some of the later payments he made to X, I don’t think this would have made a difference due to the influence X had on him and the trust he had already build up with X and the investment he thought he was making. I therefore don’t think any interventions from Revolut would have been able to break X’s spell such that Revolut could have uncovered the scam and prevented his losses. On a final note, I’ve considered whether, on being alerted to the scam, Revolut could reasonably have done anything more to recover Mr M’s losses, but I don’t think they could. The funds were sent to X via a crypto exchange provider in 2022; however, the scam wasn’t reported until 2025. In any case, the funds went to a crypto wallet in Mr M’s own name before being forwarded on to X. So, no funds would’ve remained. But even if they did, they would’ve remained in Mr M’s control and he could’ve accessed them himself. I have a great deal of sympathy for Mr M and the loss he’s suffered. I appreciate he is the innocent victim of a scam, and he has lost a significant sum of money. But it would only be fair for me to direct Revolut to refund his loss if I thought they were responsible – and I’m not persuaded that this was the case. I realise this means Mr M is out of pocket and I’m sorry he’s lost this money. However, for the reasons I’ve explained, I don’t think I can reasonably uphold this complaint. 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 Mr M to accept or reject my decision before 25 May 2026. Israr Ahmed

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Ombudsman

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