Revolut Ltd · DRN-6140990

The complaint Mrs S complains that Revolut Ltd won’t refund money she lost to a scam. Mrs S 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 S fell victim to a crypto investment scam that, as I understand, started in 2022 when she was contacted by a ‘broker’ that claimed they could provide her large returns. To do this, Mrs S purchased crypto and forwarded it to the scammer’s trading platform. Mrs S used her Revolut account to purchase crypto between September 2023 and January 2024. The relevant transactions are: Date Transaction Amount (including fees) 3 September 2023 Exchanged GBP to BTC £10 3 September 2023 Crypto withdrawal 0.00036894 BTC 27 October 2023 Exchanged GBP to BTC £5,000 27 October 2023 Crypto withdrawal 0.07015709 BTC 28 October 2023 Crypto withdrawal 0.0551426 BTC 5 November 2023 Crypto withdrawal 0.04640672 BTC Mrs S also, as I understand, made the following transactions to purchase crypto on the peer- to-peer market with a legitimate provider: Date Payment method Payee Amount 1 November 2023 Fund transfer B £5,000 1 November 2023 Fund transfer I £5,000 2 November 2023 Fund transfer A £1,424 3 November 2023 Fund transfer G £5,000 4 November 2023 Fund transfer G £5,000 5 November 2023 Fund transfer G £5,000 5 November 2023 Fund transfer G £5,000 6 November 2023 Fund transfer G £4,776 9 January 2024 Fund transfer G £1,000 10 January 2024 Fund transfer G £5,000 10 January 2024 Fund transfer G £5,000 Mrs S has explained that she realised she’d been scammed when, to be able to withdraw her funds, she was told she needed to deposit a further £100,000 – with the scammer suggesting she sell her house to do so.

-- 1 of 5 --

R complained to Revolut, on Mrs S’s behalf in September 2025 – saying Revolut failed to protect her from the scam. R wanted Revolut to refund Mrs S and pay 8% simple interest. Revolut rejected the complaint The complaint was brought to the Financial Ombudsman. Our Investigator didn’t however think Revolut were responsible for Mrs S’s loss. He said our service couldn’t consider the crypto withdrawals, but we could look at the exchange of fiat to crypto and the peer-to-peer transactions. And he considered Revolut should’ve carried out additional checks before processing the second fiat to crypto exchange transaction. But even if they had, he didn’t think this would’ve made a difference based on Mrs S’s interactions with Revolut when they intervened before processing some of the peer-to-peer transactions. This was because Mrs S didn’t answer Revolut’s questions accurately and provided misleading information. And our Investigator thought the warnings Revolut provided, based on Mrs S’s responses to their questions, were proportionate in the circumstances. He also didn’t think Revolut could’ve done anything more to have recovered Mrs S’s funds. R disagreed and so the matter 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. I’m sorry Mrs S has been the victim of a scam. I appreciate it is a lot of money she has lost and so I understand why she would do everything she can to recover it. But while I accept Mrs S has lost a lot of money due to the deception of scammers, I must consider whether Revolut are responsible for the loss she has suffered. I haven’t made my decision lightly. But while I know this won’t be the outcome Mrs S is hoping for, for similar reasons as our Investigator, I don’t think they are. So, I don’t think Revolut have acted unfairly by not refunding Mrs S. Before I explain why, I want to reassure Mrs S that I’ve considered everything R have submitted in support of her complaint. And so, while I’ve summarised this complaint in far less detail than what has been provided, I want to stress that no discourtesy is intended by this. If there is a submission I’ve not addressed, it isn’t because I have ignored the point. It’s simply because my findings focus on what I consider to be the central issue in this complaint – that being whether Revolut are responsible for any loss Mrs S suffered because of the scam. It isn’t disputed that Mrs S authorised the transactions on her Revolut account. Generally, consumers are liable for payments they authorise and Revolut are also expected to process authorised payment instructions without undue delay. However, taking into account the regulatory rules and guidance, relevant codes of practice and good industry practice, including the Consumer Duty, 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 I should however explain that for me to find it fair and reasonable that Revolut should refund Mrs S requires more than a finding that Revolut ought to have intervened. I would need to find not only that Revolut failed to intervene where they ought reasonably to have done so - 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

-- 2 of 5 --

proportionate intervention by Revolut wouldn’t have revealed the payments were part of a fraud or scam, then I couldn’t fairly hold Revolut liable for not having prevented them from being made. At which point, I’m aware that Revolut has questioned our jurisdiction to consider aspects of this complaint – as they’ve said crypto withdrawals aren’t a regulated activity, nor can the exchange of fiat currency to crypto be considered as an ancillary service to payment services in situations whereby the ultimate asset the customer receives is an unregulated crypto asset. I’ve given careful thought to Revolut’s points on this. Having done so, I don’t agree. I accept crypto withdrawals aren’t a regulated activity which means I cannot consider them in isolation. But I agree with our Investigator that the exchange of fiat money to crypto, which although not a regulated activity, is one which our service would consider ancillary to payment services. This is in the same way we consider exchanging GBP into foreign currency an ancillary activity. And I’m not persuaded that the ultimate asset being an unregulated crypto asset changes that. Therefore, given the nature of Mrs S’s complaint, I’m satisfied that I can consider whether Revolut did what they should have, in relation to her funds and account, when she used Revolut to exchange her fiat money to crypto (in addition to the peer-to-peer transactions, which are a regulated activity). And if not, whether this caused Mrs S to suffer her loss. I wouldn’t have expected Revolut to have carried out additional checks before processing the first fiat to crypto exchange transaction given its low value. However, given the fraud risk associated with crypto and as it was an increase on what Mrs S used her account for, I think there was sufficient reason for Revolut to suspect Mrs S might be at risk of financial harm when she exchanged £5,000 to BTC. Although Revolut didn’t carry out additional checks at this point, I’m aware that they did intervene before processing several of the subsequent peer-to-peer transactions. As part of these checks, it included: • Revolut told Mrs S the transactions had been identified by their system as a potential scam. And they said it was important Mrs S answered their questions about the payments honestly, and that if she was being pressured to hide any details about them or told what to say then she could be being scammed. Mrs S acknowledged this and chose to proceed. • Mrs S confirmed she wasn’t being guided or told how to send the payments. And Revolut warned that if someone was telling her to ignore these warnings, they’re a scammer. • Revolut asked why she was making the transfers, and she selected “Pay a family member or friend” each time. This was followed by selecting “Buying something from them” or “Paying back for something they purchased on my behalf”. • This prompted further questioning from Revolut, with Mrs S confirming: o The person she was buying from hadn’t asked for help unexpectedly. o On one occasion, she hadn’t paid this person before. On the other occasions, she had and she was using the same bank details.

-- 3 of 5 --

o She had been provided the bank details by phone call or face to face. • Revolut then provided various warnings to Mrs S - although, based on the purpose Mrs S provided for the payments, they were mostly tailored to purchase and impersonation scams. • Revolut also referred Mrs S to their in-app chat function on one occasion to discuss the payment further, which included: o Mrs S confirming she wasn’t being guided to make the transaction. o Mrs S explaining that she knew the person she was making the payment to, and it was to buy a car as her current one was letting her down badly. o The price of the car wasn’t cheaper than usual, she had seen proof of ownership, and she knew the seller was legitimate. I think Revolut took reasonable steps to understand the surrounding circumstances of the payments to establish if Mrs S was at risk of financial harm. Unfortunately, Mrs S didn’t provide accurate responses to Revolut’s questions – which Revolut also warned Mrs S the importance of, as well as if she was being told what to say then she could be being scammed. Consequently, Mrs S’s inaccurate answers prevented Revolut from knowing the true circumstances of the payments and the risks associated with them. At which point, I’m aware that R has said the scammer only gave Mrs S limited guidance on what to tell Revolut. And so, they don’t think there was any meaningful coaching that would’ve prevented Revolut from uncovering the scam had an effective intervention taken place. I’ve given this careful thought, particularly as, for example, I think the line of questioning and warnings Revolut should’ve provided for the £5,000 exchange to BTC transaction ought to have been tailored to the risks associated with crypto (including crypto investment scams). I’ve therefore considered whether this would’ve likely resonated with Mrs S or allowed Revolut to uncover the scam. Having done so, on balance, I’m not persuaded it would have. There is limited evidence of the correspondence between Mrs S and the scammer. I’m also aware that there were conversations between them over the telephone. Because of this, I can’t be sure of what level of coaching and guidance was provided to Mrs S. But from what I’ve seen, the ‘scam chat’ shows Mrs S was told to keep the investment a secret as a way of evading tax and even directed to “delete chats on the group and also delete our chats from time to time to avoid unforeseen circumstances”. This demonstrates, in my view, a clear direction from the scammer for Mrs S to withhold the true circumstances of the investment from other parties. I’ve also taken into consideration that in August 2022, over a year prior to the payments being disputed here, Mrs S was questioned by her other banking provider – which I’ll refer to as ‘H’ – when she tried to make a payment to a well-known crypto provider. Although I think H’s questioning could’ve gone further, as part of it, they enquired as to whether she’d spoken to anyone else about this payment. Mrs S denied this. I’m also aware that H questioned why Mrs S selected “Paying Friends & Family” rather than “Investment” as the purpose of the payment when processing it. Mrs S explained this must’ve been a mistake as it was for investment purposes. I think this further shows that Mrs S was trying to conceal the true nature of the payments she was trying to make – likely on the instruction of the scammer.

-- 4 of 5 --

I also consider it important that H’s intervention happened over a year prior. This is because I think it’s reasonable to assume that, by the point of the Revolut transactions, Mrs S would’ve been more invested – with the scammer having a greater level of influence and control over her. Consequently, it would’ve been more difficult for Revolut to have uncovered the scam. At which point, I’d like to explain that I have taken into consideration that Revolut ought reasonably to have put Mrs S’s responses under scrutiny – as they should be aware scam victims can be coached to mislead their banking providers. And so, while I wouldn’t have expected Revolut to have interrogated Mrs S about the payments she was making, I think they should’ve probed and challenged Mrs S sufficiently so that they could be reassured she wasn’t at risk of financial harm from fraud or a scam. But taking everything into account, including Mrs S’s interactions with both Revolut and H, I’m simply not persuaded – on balance – that Revolut could’ve uncovered the scam through a proportionate intervention. Ultimately, from what I’ve seen, it seems that Mrs S was being heavily influenced by the scammer – and to the degree whereby she provided inaccurate and misleading information (even when warned about the likely risk of it being a scam in that scenario). So, in these circumstances, I’m not satisfied that further intervention from Revolut would’ve broken the ‘spell’ Mrs S was under. I sympathise with Mrs S’s situation as I understand she is the innocent victim of a scam. But sadly, due to Mrs S not disclosing the true purpose of the payments she was making and providing inaccurate responses to their questioning, Revolut weren’t able to uncover the scam. It follows that I don’t think Revolut is responsible for Mrs S’s loss. I’ve considered whether, on being alerted to the scam, Revolut could’ve done anything more to recover Mrs S’s losses, but I don’t think they could. This is because the crypto purchased on the peer-to-peer market would’ve already been forwarded on to the scammer’s crypto wallet(s). And although crypto withdrawals aren’t a regulated activity which means it isn’t something I can consider, the irreversible nature of crypto transactions meant there was no method of recovery here. I know Mrs S will be disappointed by this outcome. But it would only be fair for me to direct Revolut to refund her loss if I thought they were responsible – and I’m not persuaded that this was the case. For the above reasons, I think Revolut have acted fairly and so I’m not going to tell them to do anything further. 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 S to accept or reject my decision before 20 April 2026. Daniel O'Dell Ombudsman

-- 5 of 5 --