Revolut Ltd · DRN-6247484

The complaint Mr L complains that Revolut Ltd won’t refund money that he sent as part of a blackmail scam. 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 L was contacted by a person that threatened to come to his home and harm him and his family if he didn’t send them money. Mr L has said he genuinely believed he and his family were in immediate danger. So, he made two push-to-card transactions from his Revolut account - £790 and £1,195 – on 20 October 2025. Shortly after making the second payment, Mr L reported the matter to the police and notified Revolut. He subsequently raised a complaint with Revolut, which they rejected. The complaint was referred to the Financial Ombudsman. Our Investigator didn’t think Revolut were responsible for Mr L’s loss. He said Revolut did carry out additional checks before processing one of the payments, and provided warnings based on the responses he provided. And he thought this was proportionate to the risk at the time. Our Investigator also didn’t think Revolut could’ve done anything more to recover Mr L’s funds. Mr L 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 Mr L has been the victim of a blackmail scam. I appreciate this would’ve been highly distressing and I sympathise greatly. But I must consider whether Revolut are responsible for the loss Mr L suffered. And although there are certain obligations on Revolut to protect consumers and prevent losses to scams in certain circumstances, these are not absolute. And so, there are unfortunately occasions where a consumer will lose out but have no recourse to a refund. Having carefully considered what happened here, and while I know this won’t be the outcome Mr L is hoping for, I don’t think Revolut are responsible for his loss. I therefore don’t think Revolut have acted unfairly by not refunding the payments. Before I explain why, I want to reassure Mr L that I’ve considered everything he has submitted in support of his 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 Mr L suffered because of the scam.

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In broad terms, the starting position in law is that an Electronic Money Institution – like Revolut - is expected to process payments that their customer authorises them to make. I understand that Mr L says he made the payments under coercion and intimidation, which meant he didn’t truly consent to them being made as he sent the money due to fear of what would happen if he didn’t. Although I appreciate Mr L’s intent was to protect his family, I’m satisfied that he knowingly instructed Revolut to make the payments – and that he understood the funds would leave his account in line with his request(s). So, while I appreciate Mr L says he acted under duress, I’m satisfied he authorised the payments being disputed here. Therefore, under the Payment Services Regulations and the terms of his account, Revolut are expected to process Mr L’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, 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’ve considered whether the instructions given by Mr L to Revolut (either individually or collectively) were unusual enough to have expected additional checks to be carried out before the payments were processed. When considering this, I’ve kept in mind that Revolut 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 them to carry out additional checks before processing every payment. There was minimal account activity on Mr L’s account since it was opened in July 2024. So, Revolut would’ve found it difficult to determine whether the payments were out of character for Mr L. This however didn’t prevent Revolut from assessing whether the activity was otherwise suspicious or if it potentially carried a known fraud risk. Here, the payments were relatively low value – about £1,900 in total. They also weren’t being made to payee that carried a known fraud risk (such as, for example, crypto related). Nor have I seen anything to show Revolut had been put on notice of any fraudulent activity linked to the payee. Because of this, I don’t think there was enough reason for Revolut to have suspected the payments presented a heightened risk of financial harm from fraud. Nevertheless, I’m aware that Revolut did carry out additional checks before processing the first payment (£790). This involved automated questioning to allow Revolut to assess the risk the payment presented, along with warnings tailored to Mr L’s responses being provided. Unfortunately, Mr L didn’t respond positively to the warnings – which included Revolut telling him not to proceed if he was being pressured to make the payment and that he may not get his money back if it turned out to be a scam. Revolut also put a three hour hold on the payment to give Mr L more time to think about it – and they recommended, amongst other things, for Mr L to get a second opinion from a friend of family member. I think this proportionate response was more than proportionate to the risk associated with the payment in these circumstances. So, upon Mr L confirming he wished to proceed, I think it was reasonable for Revolut to process the payment in line with his instruction. I understand Mr L thinks Revolut should’ve done more before processing the second payment – as this was made only several hours later, was of a greater value and as Revolut

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had already identified the first payment as high risk. So, Mr L thinks the second payment presented a greater risk that warranted Revolut to take further steps to protect him. I’ve given what Mr L has said careful thought. But while multiple payments made in a short period of time can be a potential indicator of fraud, it isn’t uncommon for consumers to make more than one payment to the same payee on a single day. And although the second payment was of a greater value, I consider Revolut would’ve been reassured by the fraud checks that they carried out before processing the first payment. I don’t think the level of risk here increased to a point whereby I consider Revolut would’ve have enough reason to suspect Mr L was more likely falling victim to a scam. If further payments had been made then, arguably, this might have been the case. But here, I’m not persuaded the second payment presented a heightened risk of foreseeable harm to Mr L that Revolut ought to have identified, and which required them to take further action. For completeness, even if they had, I would only reasonably have expected this to have been a further automated warning – similar to the first payment. And I see no reason to consider Mr L would’ve responded any more positively to it. It follows that I don’t think Revolut would’ve uncovered the scam or prevented Mr L from making the payment in these circumstances. I therefore don’t think Revolut is responsible for the payments being made to the scam. I’ve considered whether, on being alerted to the scam, Revolut could’ve done anything more to recover Mr L’s losses, but I don’t think they could. Revolut have shown they contacted the beneficiary bank - notifying them of the reported fraud to try and have the funds frozen in an attempt to recover it. This is all Revolut could do in the circumstances, and they were reliant on the beneficiary bank’s cooperation – as they couldn’t put a block on the account themselves or access the funds directly. Unfortunately, their recoery attempt was unsuccessful. I know Mr L will be disappointed by this outcome. I realise he is the innocent victim of a scam and I’m not trying to place any blame on him for what’s happened. 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 has 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 Mr L to accept or reject my decision before 27 April 2026. Daniel O'Dell Ombudsman

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