Revolut Ltd · DRN-6210266

The complaint Mrs K complains that Revolut Ltd won’t refund the money she lost after falling victim to a scam. What happened Mrs K had previously been the victim of a cryptocurrency investment scam, and was looking for a way to recover her losses. She came across information online about a company that said it could help, and after making an enquiry she was contacted on WhatsApp by individuals claiming to work for this company. Unfortunately, and unknown to Mrs K, these people were not legitimate, she was dealing with scammers. Mrs K was told that there was a large sum of money that she was entitled to from the previous scam being held in in a cryptocurrency wallet, Mrs K was given various documents which appeared to prove this. She was told that, to access this money, she would need to make payments for a ‘digital signature’ and an audit. On 30 June 2025 Mrs K used her Revolut account to transfer funds totalling £7,000 to a cryptocurrency account in her name, from where the funds were then sent on to the scammers. Mrs K then received further contact, purporting to be from an official body, stating that she needed to make further payments as ‘proof of funds’ before her recovered money would be returned to her. At this stage Mrs K was becoming increasingly concerned about what she was being asked to do, when Mrs K then tried to make a further payment from an account she held with another bank (‘M’) that bank stopped the payment and the scam ultimately came to light. Mrs K contacted Revolut about the scam payments, and it looked into what had happened, but it did not agree to refund any of her loss. It said it had intervened appropriately in the payments Mrs K had made but that Mrs K had not been honest about what the payments were for, so it could not have uncovered the scam. Mrs K wasn’t happy with Revolut’s response, so she brought a complaint to our service. An investigator looked into Mrs K’s complaint, they concluded that any reasonable intervention from Revolut would have been unlikely to uncover the scam, so they did not recommend that the complaint be upheld. Mrs K disagreed with the investigator’s opinion, she maintains that proper questioning and warnings from Revolut would have uncovered the scam, as they did when Bank M intervened later on. 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 reached the same overall outcome as the investigator, I’ll explain why.

-- 1 of 4 --

I’m satisfied that Mrs K authorised the payments that are the subject of this complaint. So as per the Payment Service Regulations 2017 (which are the relevant regulations in place here) that means Mrs K is responsible for them. That remains the case even though Mrs K was the unfortunate victim of a scam. From 7 October 2024 onwards, Payment Services Providers in the UK, like Revolut, have been bound by the Faster Payments Scheme (FPS) and the CHAPS reimbursement rules. Under these rules, most victims of Authorised Push Payment (APP) scams should be reimbursed – but not all types of payment are covered. Specifically, the reimbursement rules do not apply to payments made to accounts in a customer’s own control. And I am satisfied that Mrs K did have control of the cryptocurrency account that she made the payments to, so in this case the Reimbursement Rules do not apply. Because of this, Mrs K is not automatically entitled to a refund. But the regulatory landscape, along with good industry practice, also sets out a requirement for account providers to protect their customers from fraud and financial harm. And this includes monitoring accounts to look out for activity that might suggest a customer was at risk of financial harm, intervening in unusual or out of character transactions and trying to prevent customers falling victims to scams. Taking the above into consideration, I need to decide whether Revolut acted fairly and reasonably in its dealings with Mrs K, or whether it should have done more than it did. But having thought carefully about all that happened here, I am satisfied that, while it is arguable Revolut should have intervened further here, it is unlikely that would have either uncovered the scam or prevented Mrs K’s loss. I say this because Revolut intervened on two of the payments Mrs K made to the scam from her account, the first payment and the third (and final) payment. And on each of those occasions Mrs K was not honest with Revolut about what she was making the payments for. For the first payment, Mrs K was shown various warning screens which said that the payment had been identified as a potential scam payment, and made it clear that she needed to answer truthfully and that if she was being told what to say then it could be a scam. Mrs K was asked various questions and selected the options to state that she was making the payment herself and was not being pressured by anyone else. She was then asked to confirm what the payment was for and chose “I’m transferring money to my other account” as the payment purpose. Revolut asked for more detail and Mrs K indicated that she was making the payment to “My investment account”. This triggered some further questions from Revolut and in answer to Revolut’s questions Mrs K confirmed that she had discovered the investment opportunity through family/friends, that the destination account was one that she controlled, and that she had researched the investment company by checking online reviews and the FCA register. Based on what Mrs K had told it, Revolut identified that the most likely scam she could be at risk of was an investment scam, so it provided her with a warning about investment scams. For the third (and final) payment Mrs K was again taken through the same process as set out above, but Revolut then went further and asked her some additional questions about how she had found the investment and the account she was paying, including asking for proof that she had control of the account. This was then followed up with a phone call, where Mrs K was asked similar questions as had been asked on the warning screens. She again confirmed that she had found the investment via a friend that she had known for years (and had met in person), that she would not be sending the funds on to any third party from her cryptocurrency account, and that she had full control of the cryptocurrency account. During

-- 2 of 4 --

this call Mrs K made it clear that she had previously been the victim of an investment scam and so was being very cautious. I do think that Revolut should perhaps have also intervened on the second payment Mrs K made to the scam, which was by far the largest payment she made. But given that both before and after this payment she was questioned by Revolut and did not give honest answers about what she was making the payments for, it is very difficult for me to say that she would have done or said anything different if questioned about the second payment as well. Mrs K has argued that Bank M did uncover the scam when it spoke to her later on, and so Revolut could (and should) have done the same. But I don’t think that anything Mrs K said to Revolut would have indicated to it that she might be falling victim to a recovery scam, so I don’t think it did anything wrong by giving her warnings about the scam she seemed to be most likely at risk of – an investment scam. I acknowledge that, by mentioning recovery scams, Bank M was ultimately able to bring the scam to light, but I don’t think that means that there was an obligation on Revolut to do the same when everything Mrs K had told it suggested that she was making the payments as part of an investment. And Revolut’s warnings arguably did include aspects that should have resonated with Mrs K, such as warning her that if she had been told to lie to the bank (which she had) then it was likely she was being scammed. With this in mind I don’t think I can fairly say that any further, proportionate, intervention from Revolut would have stopped Mrs K from making these payments to the scam. She seems to have been very much under the spell of the scammer, hence why she was willing to be dishonest about what she was doing despite warnings about this exact issue and her past experience of scams. So, I’m satisfied that Revolut could not reasonably have prevented Mrs K’s loss here. I note what Mrs K has said about her vulnerability, and I don’t doubt that this contributed to her falling victim to this scam. But this vulnerability would only entitle Mrs K to a full refund of her loss if we were considering these payments under the Reimbursement Rules, and as set out above, I am satisfied the Reimbursement Rules do not apply in this case. Of course, any bank, including Revolut, should still be on the look out for potentially vulnerable customers, and ensure any vulnerabilities that are identified are taken into consideration. But in this case, I cannot see that Revolut was aware of Mrs K’s vulnerabilities until after the scam had already taken place. And from listening to her conversation with Revolut I don’t consider that there would have been any clear indications that she was vulnerable that should have prompted Revolut to question her further about her circumstances. So, I’m satisfied that Mrs K’s vulnerabilities don’t mean that she is entitled to a refund of her loss in this case. I also don’t think that Revolut could have done anything to recover these funds once Mrs K reported the scam. Mrs K had made the payments to a cryptocurrency account in her own name, from where they were then moved on to the scammer, so there was no route via which Revolut could have reasonably requested the funds to be returned to Mrs K’s Revolut account. I don’t doubt that Mrs K has been the victim of a cruel scam here, and I know that she has lost a large amount of money and this has had a significant personal impact on her. But I’ve not seen anything to make me think it would be reasonable to hold Revolut liable for Mrs K’s loss.

-- 3 of 4 --

My final decision I do not uphold this complaint. Under the rules of the Financial Ombudsman Service, I’m required to ask Mrs K to accept or reject my decision before 14 May 2026. Sophie Mitchell Ombudsman

-- 4 of 4 --