Amazon Payments UK Limited · DRN-6109785

The complaint A company, which I’ll refer to as Z, complains that Amazon Payments UK Limited (“APUK”) wrongly deactivated its account for a period and withheld its funds. What happened Z is a seller on Amazon. When holding a seller account with Amazon, the seller enters into an Amazon Services Europe Business Solutions Agreement with Amazon EU SARL (“AEU”). The seller also enters into a Selling on Amazon Payments User Agreement with APUK. This agreement allows the seller to receive payments for online purchases made through the Selling on Amazon Service, and to transfer funds received for online purchases to a bank account. Between May 2020 and March 2025, Z’s seller account was suspended. When the account was reactivated, the funds were disbursed to Z. The company complains that the funds were withheld wrongly, and to put things right it would like compensation for part of the time the funds were frozen. Z complained to APUK but was unhappy with the response, so it referred the matter to us. APUK said the funds were withheld because there had been a dispute between Z and AEU over the company’s supply chain. Having looked at the evidence, our investigator concluded that APUK hadn’t acted unfairly. She gave the following reasons, in summary:  AEU asked Z to verify the authenticity of its products and supply chain. The information supplied by Z in response didn’t meet AEU’s verification requirements and AEU therefore took enforcement action in May 2020.  We can consider this complaint about APUK, as it’s regulated by the Financial Conduct Authority for carrying on payment services. But we can’t investigate the actions of AEU because its activities fall outside the jurisdiction of the Financial Ombudsman Service in this complaint.  The investigator was satisfied that APUK restricted access to Z’s funds in line with the relevant terms and conditions in the Selling on Amazon Payments User Agreement.  Z’s representative argued that when AEU applied a penalty charge to Z’s account in November 2023 as a result of the alleged policy violation, that marked the end of the investigation, and APUK’s withholding the seller’s GBP balance beyond that date was unreasonable and unfair because the reasons that triggered APUK’s power to withhold funds no longer existed. He therefore said APUK should pay compensatory

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interest on the balance between November 2023 and March 2026. But the investigator noted that there was still a dispute between AEU and Z until the end of February 2025 and she was satisfied that AEU had told APUK that the dispute was unresolved. She couldn’t reasonably conclude that APUK should have released the funds before March 2025. She therefore didn’t think any interest was due. Z didn’t agree with the investigator’s conclusions and asked for an ombudsman to make 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. I’m sorry to disappoint Z’s director and its representative, but I’ve reached the same conclusions as the investigator and for largely the same reasons. Under section 2.7 of the Selling on Amazon Payments User Agreement, APUK has broad discretion to restrict transactions to or from a seller’s account. In particular, when “(a) we are subject to financial risk” or “(d) any dispute exists involving your Account or transactions conducted in connection therewith.” Moreover, section 2.7 also states “We may restrict access to your Account balance for the time that it takes for us to complete any pending investigation or resolve a pending dispute.” AEU told APUK that the seller had been engaged in behaviour in violation of its agreement with AEU. Given the unresolved matters between Z and AEU over compliance with its policies, I’m satisfied that APUK’s withholding of funds was in line with the provisions of the Selling on Amazon Payments User Agreement. APUK is entitled to withhold funds in the light of information received from AEU in respect of those provisions. I therefore find that APUK didn’t act unfairly or unreasonably. I agree with the investigator that APUK isn’t required to bear responsibility for AEU’s decision making, or for any other actions of AEU. My decision on this complaint is solely about the fairness of APUK’s actions. I believe APUK made its own decisions about its activity – carrying on a payment service – but it reasonably took into account information it received from AEU. AEU isn’t the respondent to this complaint, so I haven’t considered whether its actions were fair. Nor am I able to do so. Z’s funds were released in March 2025, and there’s no evidence that AEU had asked APUK to release the funds earlier than that. It’s clear that up to that time AEU and Z were still in dispute. The funds were then released as a result of a successful appeal to AEU. For these reasons, I’m satisfied that APUK didn’t unfairly delay the release of the funds for any period and I therefore don’t require it to pay any compensatory interest on the funds released. For all the above reasons, I don’t think that APUK made an error or acted unfairly in withholding Z’s funds. My final decision My final decision is that I don’t find that Amazon Payments UK Limited acted unfairly or unreasonably and I don’t require it to take any further action to address this complaint. Under the rules of the Financial Ombudsman Service, I’m required to ask Z to accept or

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reject my decision before 20 April 2026. Colin Brown Ombudsman

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