Revolut Ltd · DRN-5913907

The complaint Mr T complains that Revolut Ltd won’t refund money he says he lost when he was a victim of a scam. Mr T is professionally represented, however, to keep things simple, I’ll refer to Mr T throughout my decision. What happened The details of this complaint are well known to both parties, so I won’t repeat them all again here. However, Mr T complains that he sent several payments from his Revolut account to what he thought was a genuine crypto investment opportunity after he fell victim to a romance / investment scam. Mr T realised he had been a victim of a scam when he was repeatedly asked for more funds and the individual, who I will refer to as the ‘scammer,’ kept making excuses for not meeting up. Mr T complained to Revolut, and his complaint wasn’t upheld. Unhappy with Revolut’s response, he raised the matter with the Ombudsman Service. One of our Investigators looked into the complaint and didn’t uphold it. The Investigator said the withdrawal of crypto from Mr T’s account wasn’t a regulated activity. But the acceptance of funds and then the exchanges were activities that this service had the power to investigate. The Investigator went on to say, Revolut gave appropriate warnings during the scam journey and as Mr T didn’t take on board the warnings and chose to continue making the payments, he didn’t think even if any further intervention or better probing questions were asked it would have made a difference, as it was clear Mr T was firmly under the spell of the individual and determined to make the payments. As an agreement could not be reached, the complaint has been passed to me for a final 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. I’m sorry Mr T has been the victim of a scam. I don’t underestimate the impact it has had on him. I therefore understand why he would do everything he can to try and cover the loss he has suffered. But I need to decide whether Revolut can fairly and reasonably be held responsible for Mr T’s loss. And I don’t think they can, I’ll explain why. Our service can’t consider every complaint that’s brought to us. The rules that say when we can look at a complaint are set out by the Financial Conduct Authority in their dispute resolution rules (DISP rules). Here Mr T exchanged funds into cryptocurrency before sending them externally. Cryptocurrency transactions are not a regulated activity so I find the sending of cryptocurrency externally is not something that I can consider.

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However, I have considered the events leading up to the sending of the funds externally. I find the accepting of deposits into Mr T’s account a regulated or otherwise covered activity and the exchange of fiat money to cryptocurrency an ancillary activity. Therefore, I’m satisfied this part of the payment journey is something that I can consider. In line with the Payment Services Regulations 2017, consumers are generally liable for payments they authorise. Revolut is expected to process authorised payment instructions without undue delay. But it also has long-standing obligations to help protect customers from financial harm from fraud and scams. Considering the relevant: law and regulations; regulators’ rules, guidance and standards; codes of practice; and, where appropriate, what I consider to be good industry practice at the time - Revolut should fairly and reasonably: • Have been monitoring accounts 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 payment service providers are generally more familiar with than the average customer. • In some circumstances, take additional steps, or make additional checks, before processing a payment, or in some cases decline it altogether, to help protect customers from the possibility of financial harm from fraud. • 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. However, as mentioned above I can only consider the events leading up to the sending of the funds externally. So, I’ve thought about whether the deposits or exchanges should have highlighted to Revolut that Mr T might be at a heightened risk of financial harm from fraud – and if so, what might’ve been expected from a proportionate intervention at that time. Here, having reviewed Mr T’s account activity 12 months prior to the disputed payments, I do agree that the exchange Mr T made on 10 May 2025, for £7,800 was unusual and a large exchange based on his previous activity, which did indicate Mr T was at risk of potential financial harm and required Revolut to take additional steps or provide warnings before processing the exchange. I also consider the exchange Mr T made on the following day (11 May 2025) for £29,800 was again of a considerable high value and should have resulted in Revolut taking further action to ensure Mr T wasn’t at risk of fraud or a scam. I’ve also taken notice of Mr T’s argument that the intervention provided by Revolut wasn’t good enough and they should have asked more probing questions which would have helped uncover the scam and prevented his loss. However, I don’t think it makes a difference here, even if I agree that Revolut should have provided a better intervention and asked more probing questions as Mr T has mentioned, because for me to find it fair and reasonable that Revolut should refund Mr T his losses require 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 to have done, or in the way they ought to have done so – but crucially I’d need to find that but for this failure the subsequent loss would have been avoided. The latter element concerns causation. A proportionate intervention will not always result in the prevention of a transaction. And if I find it more likely than not that such a proportionate intervention by Revolut wouldn’t have revealed the transaction was part of a fraud or scam,

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then I can’t fairly hold it liable for not having prevented it from being made. I can see that Revolut did intervene prior to processing some of Mr T’s cryptocurrency withdrawals including on the same day (10 May 2025) as well as other transactions he carried out later and provided him with advice and warnings to try and protect him from being scammed. I can’t assess whether those interventions were proportionate, as it happened during the part of the cryptocurrency process that doesn’t fall without our jurisdiction. But I think those interactions are a good indication of what would likely have happened if Mr T had received warnings prior to the exchanges he made above. Interventions by Revolut Here, Revolut did provide Mr T with tailored investment warnings during the payment journey. Revolut have also mentioned they informed Mr T that various payments he was attempting had been flagged by their systems as a potential scam and that to continue they needed to ask him some questions. As part of this it conducted further checks, undertaking a fraud risk assessment before allowing the payments to be processed. Revolut also spoke with Mr T on the phone on one of the payments as they were concerned that there was a high risk of the payment being fraud related. Revolut have said they asked Mr T to select the purpose of the payment from a list of options on some of the payments he was making and based on the options he selected he was shown various scam warnings. Revolut’s warnings highlighted that this could be a scam and that if he’d been told to ignore the warnings given, then it was a scam. Revolut also asked Mr T a series of questions, to narrow down the possible fraud risks he faced, including whether he’d been asked to install any software so someone could see his screen, whether he had been asked to pay someone he didn’t know. Revolut’s agent also made it clear to Mr T that his money may be at risk if he continued with the payments. I appreciate not all the warning messages Revolut provided would have seemed relevant to Mr T’s circumstances. This, however, was no fault of Revolut as it is reliant on customers providing accurate answers to the questions they ask so they can tailor the warnings that are provided. The warnings provided, albeit not all specifically tailored to the type of scam Mr T fell victim to, were relevant to his circumstances. They highlighted that he was being tricked by a convincing fraudster and if he was being guided he should stop immediately and remain vigilant. He was also told scammers often pose as financial advisers and pressure people to make payments. Scammers build trust by showing some returns and then trap victims into a cycle of continual payments. The platform Mr T had mentioned had only been active for two weeks and did not appear credible; and he was advised to do more research on it. Payments from Revolut are generally to genuine sites but scams often occur on third-party platforms, and Revolut emphasised the investment Mr T had mentioned had a “high chance of being a scam.” Based on the various warnings Revolut provided Mr T and the conversation he had with the advisor, whilst I’m sympathetic to his situation, I’m satisfied Revolut took reasonable and proportionate steps to protect him from the risk of fraud or a scam. But, sadly, Mr T failed to respond positively to the warnings he was provided. Because of this, and having reviewed the scam chat, Mr T seems to have been so heavily under the influence of the scammer at such an early stage, I’m not persuaded that Revolut would have been able to uncover the scam if it probed further or asked better questions as Mr T has suggested. I am also persuaded Mr T would have continued providing credible answers to reassure Revolut the investment was genuine, as I’ve seen no evidence the scammers influence over Mr T was starting to wane as the scam progressed, so I do not think Revolut could have prevented his loss.

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Mr T has also mentioned being vulnerable to the scam, due to being unemployed and having a recent relationship breakdown around the time of the scam. However, based on Mr T’s interactions with Revolut at the time he made the payments, and Revolut not being informed of any vulnerabilities prior to the payments being made, there wasn’t anything to indicate from his interactions with Revolut, that he was making the payments under pressure from a third party or was vulnerable at the time he made the payments. And so, I wouldn’t have expected Revolut to have done anything further in these circumstances. Mr T has referenced other decisions issued by our service to support his argument that Revolut should have done more here to protect him from financial harm. I understand why this is something Mr T would like me to consider, but each case our service looks at is reviewed on its own merits and I’m afraid I can’t comment on conclusions we’ve reached on previous complaints. I’ve also noted the comments of Mr T about the Financial Conduct Authority’s Consumer Duty and I’ve taken account of Revolut’s obligations following its introduction. But I’m not persuaded this changes the outcome here. While Revolut was expected to avoid causing him foreseeable harm, I’m not persuaded its actions (or failure to act further) were the cause of the harm he has said he suffered, nor do I think that harm was reasonably foreseeable given the information that was available to Revolut at the time Mr T made the payments. On a final note, I’ve considered whether, on being alerted to the scam, Revolut could have done anything more to recover Mr T’s losses, but I don’t think they could, as the sending of crypto isn’t a payment that can be reversed. So, there were no further means for Revolut to try and recover the crypto withdrawals. I have a great deal of sympathy for Mr T and the loss he’s suffered. 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. And so, I’m not going to tell Revolut 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 T to accept or reject my decision before 21 April 2026. Israr Ahmed Ombudsman

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