Revolut Ltd · DRN-6054173

The complaint Ms D complains that Revolut Ltd won’t refund money she lost when she was the victim of a scam. What happened The background to this complaint is well known to both parties, so I won’t repeat everything here. In summary, Ms D fell victim to a task-based job scam in which she was required to complete tasks in exchange for commission. Ms D has advised her and her aunt came across a job role on a social media site. Ms D made contact with a recruiter (who I will refer to as “the scammer”) and believed this was a legitimate opportunity. She was told she needed to make payments as part of the role for various reasons. Ms D made two payments for £290 and £710 in October 2025. She realised she had been the victim of a scam when the scammer requested further funds. Ms D raised a complaint with Revolut. It didn’t think it had done anything wrong by allowing the payments to go through. So, Ms D brought her complaint to our service. Our Investigator looked into the complaint but didn’t uphold it. Our Investigator didn’t think the payments Ms D made were unusual and so she didn’t feel Revolut should have identified a scam risk. However, our Investigator explained that Revolut had provided warnings to Ms D before releasing one of the payments, but she provided incorrect information when asked about it. Overall, the Investigator thought the actions taken by Revolut were proportionate to the risks it identified. Ms D didn’t agree, so her complaint has been passed to me for review and 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. Having done so, I’ve come to the same outcome as the Investigator for largely the same reasons. I’ll explain why. I’m aware that I’ve summarised this complaint briefly, in less detail than has been provided, and in my own words. No discourtesy is intended by this. Instead, I’ve focussed on what I think is the heart of the matter here. If there’s something I have not mentioned, it isn’t because I have ignored it. I haven’t. I’m satisfied that I don’t need to comment on every individual point or argument to be able to reach what I think is the right outcome. Our rules allow me to do this. This simply reflects the informal nature of our service as a free alternative to the courts. 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

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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 in October 2025 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 (among other things). This is particularly so given the 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 the fraudulent practices are evolving and the different risks these can present to consumers, when deciding whether to intervene. However, I’d expect any intervention to be proportionate to the circumstances of the payment. I have kept in mind that EMI’s such as Revolut process high volumes of transactions each day, and that there is a balance to be found between allowing customers to be able to use their accounts and questioning transactions to confirm they are legitimate. The account was opened just before the scam so there was limited account activity prior to the transactions in question, so it is difficult for me to agree that Revolut should have identified the transactions as ‘out of character’ for Ms D. The payments made towards the scam were fairly modest and although there were two payments made on the same day they did not increase significantly in value (which can sometimes happen when a customer is falling victim to a scam). I appreciate that the payments may have represented a lot of money to Ms D but they were simply not of a value where I’d usually expect Revolut to be concerned that Ms D was at a heightened risk of financial harm. The payments were also made to a legitimate cryptocurrency provider. And while there are known fraud risks associated with cryptocurrency, as scams like this have unfortunately become more prevalent, not all payments related to cryptocurrency are scam related. This means that I wouldn’t expect Revolut to intervene on a payment just because it related to cryptocurrency. Although I don’t think the payments suggested Ms D was at risk of financial harm from fraud such that Revolut ought to have intervened, Revolut have confirmed that it did intervene on one of the payments, so I’ll comment on the interventions. It provided Ms D with advice and warnings to try and protect her from being scammed. As part of this it asked if Ms D was being pressured to make the payments or told to ignore any warnings and that if someone was telling her to do this then it’s likely to be a scam. It asked if the money was going to an account Ms D controlled. It also highlighted this could be an investment scam, beware of

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social media promotions, don’t give anyone remote access, do your research and don’t be rushed. It’s clear that Ms D gave inaccurate information in order to get the payments processed. She’s since confirmed that she was being guided and that the funds were not going to an account she had control over. But I think these warnings highlighted several key features which applied to Ms D’s payments so the information should have resonated with her and prompted her to question the legitimacy of what she was being asked to do. In the circumstances Revolut were prevented from knowing the true purpose of the payments. And so, I don’t think it acted unreasonably by providing the scam warnings it did. I’m also satisfied the warnings Revolut presented were appropriate and proportionate to the risks identified by it at the time. So, I don’t think there is anything further I would have expected Revolut to have done before processing the payments. I’ve also considered whether Revolut could have done anything to recover Ms D’s payments once the scam was uncovered. It attempted recovery of Ms D’s funds but cryptocurrency was moved into the control of the scammers. So, I don’t think there was any realistic prospect of Revolut recovering the funds. I’m sorry to hear Ms D suffered a financial loss as a result of what happened. But it would only be fair for me to direct Revolut to refund her loss if I thought it was responsible – and I’m not persuaded that this was the case. For the above reasons, I think Revolut has acted fairly and so I’m not going to tell it to do anything further. My final decision For the reasons I’ve explained, I do not uphold this complaint. Under the rules of the Financial Ombudsman Service, I’m required to ask Ms D to accept or reject my decision before 28 April 2026. Aleya Khanom Ombudsman

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