Revolut Ltd · DRN-6042918

The complaint Mr G complains that Revolut Ltd will not refund money he lost when he was a victim of an investment scam. Mr G is professionally represented, however for ease, I’ll refer to Mr G throughout my decision. What happened The background to this complaint is well known to both parties and so I’ll only refer to some key events here. Mr G has explained that he fell victim to an investment scam in 2025, whereby he came across a firm, which I’ll refer to as ‘X’, advertised on social media referring to an investment opportunity. As part of this alleged scam, Mr G made payments to a genuine crypto exchange from his other banking provider, which I will refer to as ‘L’, as well as sending funds from L to Revolut, before making numerous payments to various genuine crypto exchange providers from Revolut, which the scammers helped him set up using remote access software, that was subsequently lost to the scam. In total Mr G made twenty-one transactions to X from his Revolut account totalling just over £33,000 between 20 December 2024 and 30 January 2025. Mr G has also raised a complaint against L, which I will address separately. Mr G realised he’d been scammed when, he attempted to withdraw his investment and he kept being told by X to make numerous payments of increasing value for various withdrawal fees. Mr G raised a complaint with Revolut, which they didn’t uphold, so the matter was referred to our service. Our Investigator didn’t uphold the complaint. She said, Revolut and L made several proportionate interventions. And she didn’t think any further interventions would’ve uncovered the scam or prevented Mr G from sending the funds and based on the answers he provided to the various interventions, she didn’t think Revolut needed to do anything else. Mr G didn’t agree and said Revolut should have done more to protect him from the investment scam he fell victim to. As no agreement could be reached, Mr G’s complaint 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 Mr G has been the victim of a scam, and I don’t underestimate the impact this has had on him. But while I’m sympathetic to Mr G’s circumstances, I must consider whether Revolut is responsible for the loss he has suffered. I know this won’t be the outcome Mr G is hoping for, but for similar reasons as our Investigator, I don’t think they are. And so, I don’t

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think Revolut has acted unfairly by not refunding the payments. I’ll explain why. Firstly, I’ve thought about the CRM code which can offer a potential means of obtaining a refund following scams like this one. But as Revolut isn’t a signatory of the CRM code, these payments aren’t covered under it. I’ve therefore considered whether Revolut should reimburse Mr G under any of their other obligations. In broad terms, the starting position in law is that an electronic money institution (EMI) is expected to process payments that their customer authorises them to make. It isn’t disputed that Mr G knowingly made the payments from his account and so, I’m satisfied he authorised them. Therefore, under the Payment Services Regulations 2017 and the terms of his account, Revolut are expected to process Mr G’s payments, and he is presumed liable for the loss in the first instance. However, taking into account the regulatory rules and guidance, relevant codes of practice and good industry practice, 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. When considering this, I’ve kept in mind that EMIs process high volumes of transactions each day. And that there is a balance for Revolut to find between allowing customers to be able to use their account and questioning transactions to confirm they’re legitimate – as it wouldn’t be practical for EMIs to carry out additional checks before processing every payment. I need to decide if Revolut acted fairly and reasonably in their dealings with Mr G when he made the payments. Specifically, whether they should’ve done more than they did before processing them – and if they had, would that have made a difference. But for me to find it fair and reasonable that Revolut should refund Mr G requires more than a finding that Revolut ought to have intervened or done more, 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 proportionate intervention by Revolut wouldn’t have revealed the payments were part of a fraud or scam, then I couldn’t fairly hold them liable for not having prevented them from being made. Revolut’s interventions Here, Mr G was provided with the following warning each time he attempted to make a payment to a new beneficiary: “Do you know and trust the payee? If you’re unsure, don’t pay them, as we may not be able to help you get your money back. Remember, fraudsters can impersonate others, and we will never ask you to make a payment.” Once Mr G acknowledged the above warning, Revolut have mentioned they still had concerns about numerous payments he made, and asked him a series of questions, across seven different transactions he attempted. I won’t go into detail about the responses Mr G provided, however, I’ve summarised some of his responses below: o He’s transferring money to his other account.

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o He wasn’t asked to install software. o Nobody told him his account isn’t safe. o The money is going into an account he controls. Mr G was also shown the following warning on a few occasions by Revolut: “If someone is telling you to ignore these warnings, they’re a scammer – only continue if you’re sure nobody is pressuring you to make this payment.” Mr G still confirmed he wanted to continue with the payments. Based on the answers Mr G provided, he was shown various warnings by Revolut, some of which were not relevant to his situation. However, this was based on the answers Mr G provided to the questions he was asked. So, Revolut rely on customer’s providing honest answers to the questions they are being asked. For example, Mr G had the option to select, he was making payments ‘as part of an investment,’ on various occasions, however, he chose the option which said, ‘transfer to my other account’ on each occasion, which resulted in warnings being provided for safe account scams and impersonation scams. Some of the warnings were still relevant to Mr G’s situation, as they highlighted the risks of unexpected calls, not giving anyone remote access, being told to ignore warnings, to name a few. On 8 January 2025, when Mr G attempted a £3,000 payment from his Revolut account to a crypto exchange provider, after answering a series of questions he was asked by Revolut, Mr G was directed to their in-app chat as they were not satisfied with the answers he provided. Mr G provided the following responses to the questions he was asked: o He is transferring money to his saving account. o He isn’t investing in cryptocurrency; he is just transferring money to a different account for deposit. (Revolut asked for a screenshot of the account he was sending the money to, which Mr G duly provided) o No one has contacted him asking him to take urgent action, such as to pay a fine and he hasn’t been legally threatened with imprisonment. o No one has asked him to install remote control applications like Anydesk or Teamviewer. o He was transferring funds from his L account to another account and he wants this transfer to be completed as he is making the transfer to his own account, and this is not fraud. On 17 January 2025, Mr G was again directed to the in-app chat when he attempted a payment of £399 to a known crypto provider. Revolut asked Mr G to provide a screenshot of the account the payment is going to, which he did. Mr G mentioned this was not an investment account and it’s just his own account where he can buy crypto when he wants to, so he asked Revolut to complete their checks and let him use his own Revolut account. Based on the information provided, Revolut were not satisfied with the answers Mr G provided, so a phone call was initiated with him. Mr G provided the following responses to the Revolut advisor on the call: o He created his Revolut account to move money to his other account and sometimes buy crypto. o The Revolut account was recommended to him by his friends, because many of his relatives have Revolut accounts, as it’s easier to use abroad. o He’s been dealing with crypto for one year. o He’s aware of how crypto works. o His friend recommended him to buy crypto and he is helping him.

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o After moving the funds into the crypto account, he will leave it there and he will put it all back into his Revolut account. o He’s satisfied the payment he is making is genuine, and he is aware of the high risk involved in proceeding with the payment, and he is prepared to lose all his money if the payment turns out to be a scam. Revolut then provided him with warnings about the high-risk nature of crypto investments as well as crypto investment scam warnings, and Mr G confirmed he was not falling victim to a scam and was happy for the payment to be processed. L’s interventions I’ve also considered, Mr G’s interactions with L, which included two phone calls that took place on 12 December 2024, before he started making payments to X from his Revolut account, where L had concerns Mr G could be falling victim to a scam. On the first call, Mr G told the L advisor, he was sending money to his own account and no one had asked him to open the account. Mr G was asked about the reason for the payment, which he said: “from that bank it's easier in my country to use this because I will fly soon to my country. From L I had last time problem.” Based on the answers he was providing, L removed the blocks on his account. On the second call Mr G had with L, he again mentioned he was making a payment to his own account, and confirmed he hadn’t received any strange telephone calls, or messages about asking him to move the money or lie to his bank. He also confirmed that he hadn’t been asked to invest his money. He explained that he was flying to his country in December and he would use the account there. He confirmed that nobody was asking him to make the payment, so the payment was made successfully. I will not set out the specifics of the conversations Mr G had with X here, as he is already familiar with it. But having looked at it, it’s very clear that he was being heavily coached and influenced by X from the start of the scam. This is evident from Mr G being guided by X on how to handle any interventions and given the answers Mr G provided at the time it’s clear he was being guided by X in his responses. It’s also evident Mr G sought advice from X which he followed, which meant Revolut were unable to uncover the scam. I therefore don’t think any further interventions from Revolut would have been able to counter the heavy coaching Mr G was receiving from the scammer or break the scammer’s spell such that Revolut could have uncovered the scam and prevented his losses. On a final note, I’ve considered whether, on being alerted to the scam, Revolut could reasonably have done anything more to recover Mr G’s losses, but I don’t think they could. Revolut attempted to recover the faster payments which Mr G sent to the crypto wallets, but unfortunately, at the time he reported the scam, the funds had already been removed from the receiving accounts. In relation to the card payments Mr G made, the funds were sent to crypto wallets in Mr G’s own name before being forwarded on to X. So, the only option to recover the card payments was via the chargeback process. However, as the funds had already been moved onto X, no funds would’ve remained. But even if they did, they would’ve been in Mr G’s control and he could’ve accessed them himself. Also, the chargeback rules don’t cover scams. I have a great deal of sympathy for Mr G and the loss he’s suffered. And I appreciate he is the innocent victim of a scam, and he has lost a significant sum of money. But it would only be fair for me to direct Revolut to refund his 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.

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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 Mr G to accept or reject my decision before 27 April 2026. Israr Ahmed Ombudsman

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