Revolut Ltd · DRN-6059715

The complaint Miss P complains that Revolut Ltd won’t refund funds she’s lost as a result of a scam. What happened The facts of the case are well known to both parties so I’ll only give a brief summary below. Miss P was sadly the victim of a job scam. She also made payments to the ‘scammers’ via four other financial businesses – I’m considered the payments Miss P made to three of these other businesses in separate decisions. The fourth business refunded Miss P’s losses. Miss P was contacted via social media and invited to take a ‘job’ reviewing adds. Miss P agreed to take part and initially received what she thought were salary payments from the role. However, Miss P was then asked to make payment to allow her to access job tasks and the commission she’d made. Unfortunately, on being unable to access her funds Miss P realised she’d been scammed. In total Miss P sent around £3,500 to the scammers via her Revolut account. Miss P complained to Revolut but they didn’t uphold her complaint. In summary Revolut argued that on 4 November 2024 they intervened and asked Miss P a series of questions regarding her payments, they issued some general scam guidance and warned Miss P via the live chat and over the phone that she was likely the victim of a scam. One of our Investigators considered Miss P’s complaint but didn’t uphold it. They thought the intervention Revolut carried out was proportionate to the risk identified and they wouldn’t expect Revolut to do anymore when attempting to recover her funds. Miss P didn’t agree so the case has been passed to me to decide. 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. In broad terms, the starting position at law is that an Electronic Money Institution (“EMI”) such as Revolut is expected to process payments and withdrawals that a customer authorises it to make, in accordance with the Payment Services Regulations (in this case the 2017 regulations) and the terms and conditions of the customer’s account. But, taking into account relevant law, regulators’ rules and guidance, relevant codes of practice and what I consider to have been good industry practice at the time, I consider it fair and reasonable that Revolut should: • have been monitoring accounts and any payments made or received to counter various risks, including preventing fraud and scams; • have had systems in place to look out for unusual transactions or other signs that might indicate that its customers were at risk of fraud. This is particularly so given the

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increase in sophisticated fraud and scams in recent years, which firms are generally more familiar with than the average customer; • have acted to avoid causing foreseeable harm to customers, for example by maintaining adequate systems to detect and prevent scams and by ensuring all aspects of its products, including the contractual terms, enabled it to do so; • in some circumstances, irrespective of the payment channel used, have taken additional steps, or made additional checks, or provided additional warnings, before processing a payment; • have been mindful of – among other things – common scam scenarios, how fraudulent practices are evolving (including for example the common use of multi- stage fraud by scammers, including the use of payments to cryptocurrency accounts as a step to defraud consumers) and the different risks these can present to consumers, when deciding whether to intervene. When considering whether a warning should be provided the nature and extent of that warning should be proportionate to the risk the payment presents and strike a balance between trying to protect customers and not unduly inconveniencing them. I must also consider that applying significant friction to all payments would be very onerous and would likely be impractical for Revolut. Should Revolut have recognised that consumer was at risk of financial harm from fraud? I’m satisfied that I wouldn’t have expected Revolut to have identified that the payments made between 1 and 3 November 2024 carried a heightened risk of financial harm or fraud. I say this because the payments aren’t unusually large or otherwise suspicious. However I’m satisfied that the payments made on 4 November 2024 should have triggered. And I can see that Revolut did intervene on these payments initially by asking Miss P to fill out a series of questions prior to speaking with her on the in app chat and by phoning Miss P. I’ve listened to the call Revolut had with Miss P on 4 November 2024, and during the call the advisor identified that Miss P was highly likely to be the victim of an advance fee scam. Specifically the advisor said: “No company will request that you put your own money in order to complete tasks, if you are requested to do most probably you are being scammed” and “Very big red flags you have fallen victim to a scam” Revolut then followed up with an email which Miss P also shared another one of her banks to advise them she’d been scammed. I’m satisfied that Revolut carried out a proportionate intervention when phoning Miss P and advising her that she’d likely been the victim of a scam. Unfortunately, despite this intervention Miss P made further payments to the scammers. Even if I thought Revolut should have intervened further at this point I can’t fairly say it would have led to Miss P not making any further payments to the scammers. I say this based on the clear and proportionate warnings Revolut gave Miss P over the phone and via the in app chat. For completeness I’ve considered whether Revolut did what I’d expect in attempting to

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recover Miss P’s funds. And I’m afraid I’m satisfied they did. Miss P made some of the scam payments using her debit card – the usual route to recovery here would be via a chargeback. Unfortunately, a business is only required to raise a chargeback if there’s a reasonable prospect of success – in this case I’m satisfied a chargeback would likely fail as the money remittance service provided the service expected, in receiving the funds and passing them on as per Miss P’s instructions. As the faster payments made all went to accounts in Miss P’s name I wouldn’t expect Revolut to make attempts to recover them. Overall, while I understand this will be very disappointing for Miss P, I’m afraid I won’t be asking Revolut to do anything further here. I acknowledge that Miss P has been the victim of a cruel scam but being the victim of a scam doesn’t automatically mean that Revolut are obligated to refund her. My role is to make an impartial judgement on a fair and reasonable basis about whether Revolut have done what they are expected to do. And if they haven’t, would Revolut taking the correct action have prevented the scam or successfully recovered Miss P’s funds. There is a third party involved – the scammers – who tricked Miss P and caused the loss she suffered. As I’ve determined in this case Revolut isn’t at fault and couldn’t reasonably have prevented Miss P’s loss it wouldn’t be fair or reasonable for me to ask Revolut to provide a refund for actions carried out by the scammers. My final decision My final decision is I don’t uphold this complaint. Under the rules of the Financial Ombudsman Service, I’m required to ask Miss P to accept or reject my decision before 28 April 2026. Jeff Burch Ombudsman

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