Revolut Ltd · DRN-6171602

The complaint Mr W complains that Revolut Ltd (Revolut) is refusing to refund him the amount he lost as the result of a scam. Mr W is being represented by a third party. To keep things simple, I will refer to Mr W throughout my decision. What happened The background of this complaint is well known to all parties, so I won’t repeat what happened in detail. In summary, Mr W has told us that he was contacted by what appeared to be the director of a company I will call “X” via a well-known messaging application. X appeared to specialise in cryptocurrency recovery. Mr W carried out some online research which reassured him that X was legitimate. X advised Mr W that it had identified a frozen wallet holding funds that had been referenced by previous scammers held in the name of a company called Geselar and that to access those funds a gateway needed to be created between Mr W’s account and Geselar’s account. X put Mr W in touch with an individual I will call “Y” who X said worked for Revolut. Y was going to assist in recovering Mr W’s funds. Mr W made payments as requested but each time he made a payment more funds were requested. When Mr W’s funds had been depleted X advised Mr W to release equity from his house to fund further payments. It was at this stage that Mr W realised he had fallen victim to a scam. What I can and can’t look into in relation to this complaint Our service can’t consider all complaints that are referred to us. The rules under which we operate are set out in the Financial Conduct Authority’s Handbook and are collectively known as the DISP rules. We can only consider complaints that fall within our jurisdiction, in line with these rules. Particularly relevant to Mr W’s complaint is DISP 2.2 which states: “DISP 2.2: Which complaints can be dealt with under the Financial Ombudsman Service? 2.2.1 The scope of the Financial Ombudsman Service's two jurisdictions depends on: (1) the type of activity to which the complaint relates…” Those activities are then listed in DISP 2.3 (although I will not list all of them here). We can only consider complaints that relate to an act or omission by a financial business in carrying out one or more of the activities listed in DISP 2.3. Cryptocurrency isn’t electronic money or fiat currency according to the Financial Conduct

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Authority. Instead, it classifies cryptocurrency, and similar cryptocurrency-assets, as ‘exchange tokens’. The operation of cryptocurrency services isn’t currently regulated by the financial regulator in the UK. There are no activities listed in DISP 2.3 which would cover the activity this part of Mr W’s complaint relates to – namely, withdrawing the cryptocurrency and sending it on to the scammer. And so, I don’t think his complaint in relation to the cryptocurrency payments relates to an activity covered by us. I am mindful that Mr W deposited fiat currency to his Revolut account and then exchanged this into the cryptocurrency which was withdrawn and ultimately lost to the scam. But the sending of the cryptocurrency was provided separately from the provision of Mr W’s main e- money account. In the circumstances, I don’t consider Revolut’s provision of sending cryptocurrency services to be sufficiently closely linked to its provision of payment services to Mr W (through the provision of his e-money account) that it should be deemed ancillary to this. So, I’m satisfied that this service is unable to investigate the withdrawal of cryptocurrency here. What I can look at, is whether Revolut should have intervened when the deposits into Mr W’s account were made and when the funds were converted into cryptocurrency. I can also look at payments Mr W made directly to another account in another name. Mr W made the following exchanges into cryptocurrency within the Revolut platform: Exchange Date Amount Exchange to 1 1 August 2025 £49,900.00 USDT 2 1 August 2025 £50.00 BTC 3 15 September 2025 £505.44 USDT 4 17 September 2025 £1,006.52 USDT 5 19 September 2025 €2,600.00 BTC 6 23 September 2025 €7,210.20 BTC 7 23 September 2025 0.01817044 BTC USDT 8 29 September 2025 €413.85 BTC 9 2 October 2025 €2,580.00 BTC 10 7 October 2025 €634.00 BTC Having exchanged funds into cryptocurrency Mr W went on to make the following cryptocurrency withdrawals and received multiple warnings: Withdrawal Date Currency Amount Warning 1 1 August 2025 USDT £137.21 (176 USDT) 2 1 August 2025 USDT £1,891.05 (2481 USDT) Written educational warning 3 15 September 2025 USDT £504.71 (672.95 USDT) Written educational warning 4 17 September 2025 BTC £1,007.91 (1355.71USDT) 5 8 September 2025 BTC £16.34 (0.00015000 BTC) Written educational warning 6 19 September 2025 BTC £1,662.53 (0.01900000 BTC)

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7 19 September 2025 BTC £578.59 (0.00659000 BTC) 8 25 September 2025 BTC £423.21 (0.00500000 BTC) Live chat and phone call 9 26 September 2025 BTC £482.31 (0.01200000 BTC) 10 26 September 2025 BTC £995.79 (0.00580000 BTC) 11 29 September 2025 BTC £1,868.85 (0.02210000 BTC) 12 1 October 2025 BTC £1,178.49 (0.01357256 BTC) 13 1 October 2025 USDT £1,094.57 (1,457.32 USDT) Written educational warning 14 2 October 2025 BTC £2,198.95 (0.02433684 BTC) 15 7 October 2025 BTC £538.23 (0.00570982 BTC) Written educational warning Mr W also made the following international transfers: Payment Date Payee Payment Method Amount Warning 1 4 August 2025 Geselar Sp. zoo International transfer £34,870.00 Live chat and phone call 2 5 August 2025 Geselar Sp. zoo International transfer £10,758.00 3 11 August 2025 Geselar Sp. zoo International transfer £24,431.00 4 12 August 2025 Geselar Sp. zoo International transfer £43,230.00 5 13 August 2025 Geselar Sp. zoo International transfer £43,234.00 6 14 August 2025 Geselar Sp. zoo International transfer £43,107.00 7 15 August 2025 Geselar Sp. zoo International transfer £11,451.70 8 16 August 2025 Geselar Sp. zoo International transfer £43,175.00 9 18 August 2025 Geselar Sp. zoo International transfer £17,534.13 10 19 August 2025 Geselar Sp. zoo International transfer £8,761.35 Our Investigator considered Mr W’s complaint and didn’t think it should be upheld. Mr W disagreed, so this 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.

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It has not been disputed that Mr W has fallen victim to a cruel scam. The evidence provided by both Mr W and Revolut sets out what happened. What is in dispute is whether Revolut should refund the money Mr W lost due to the scam. Recovering the payments Mr W made Mr W has disputed payments made from his account via international transfer. When payments are made by transfer Revolut has limited options available to it to seek recovery. I can see that Revolut did contact the operator of the recipient account but the attempt to recover funds was unsuccessful. The remaining funds lost to the scam were lost when cryptocurrency withdrawals were made. As I have already explained above, I am unable to consider these losses. With the above considered I am unable to say that Revolut should have done more to recover the payments Mr W has disputed. Should Revolut have reasonably prevented the payments Mr W made? It has been accepted that Mr W authorised the payments that were made from his account with Revolut, albeit on X and Y’s instruction. So, the starting point here is that Mr W is responsible. However, banks and other Payment Services Providers (PSPs) do have a duty to protect against the risk of financial loss due to fraud and/or to undertake due diligence on large transactions to guard against money laundering. The question here is whether Revolut should have been aware of the scam and intervened when Mr W made the payments. And if it had intervened, would it have been able to prevent the scam taking place. I will look at each type of payment. Deposits In general, I wouldn’t expect Revolut to have concerns about deposits being made into a customer’s account and interventions to take place Unless they had money-laundering concerns which it didn’t have on this occasion. So, I don’t think it was unreasonable that Revolut didn’t intervene when payments were made into Mr W’s account. Exchanges made into cryptocurrency When Mr W made exchanges into cryptocurrency from within the Revolut platform he remained in control of the funds. But some of the exchanges (exchange 1 and 6) were substantial and related to cryptocurrency (payments that have a higher associated risk). I think Revolut should have had concerns Mr W could have been at risk of financial harm when these exchanges were made and it should have intervened. I think a proportionate intervention to the risk associated with these exchanges would have been for Revolut to have discussed the exchanges with Mr W and to have provided an appropriate warning based on the information he provided. International Transfers All the international transfers Mr W made in relation to the scam were significant in value. Considering the value of the payments I think Revolut should have had concerns Mr W could have been at risk of financial harm when the payments were made and it should have

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intervened. I think a proportionate intervention to the risk associated with these payments would have been for Revolut to have discussed the payments with Mr W and to have provided an appropriate warning based on the information he provided. At this point I think it’s important to point out that in June and July 2025, before this scam took place, Mr W had fallen victim to a similar scam where he was contacted out of the blue with the promise of retrieving a lost investment. Mr W made multiple payments to retrieve the funds via accounts held with two different businesses. Mr W received very clear warnings when making payments from another of his accounts and was told he was falling victim to a scam. Despite this clear warning Mr W went onto make payments in relation to the scam from another of his accounts providing false information to have the payments processed. When Mr W made the payments in relation to this scam, he ignored the warnings that were provided to him in relation to the previous scam that very clearly applied to these circumstances as well. In addition to the above Revolut intervened on multiple occasions when Mr W made cryptocurrency withdrawals and when he made international transfers. From the table above you can see that Revolut provided educational warnings for many of the exchanges. When Mr W made these payments, he was asked automated questions. Mr W confirmed he was not being pressured to make the payments, he was not following any instructions, he understood that investments offering high returns were likely to be a scam, if he was sending money to accounts he didn’t own he was likely being scammed, he had carried out his own research and he had answered the questions honestly. Revolut also intervened on two other occasions and calls took place between Mr W and Revolut. When Mr W attempted the first international payment a call took place. Revolut explained that it thought Mr W may have been tricked by convincing fraudsters trying to steal his money. Revolut first discussed a cryptocurrency transaction, Mr W explained: • He had found the opportunity primarily by himself but also by a good friend of his. He had started researching on his own and was giving it a try • No one had assisted him with the transaction • He wasn’t sure what he would invest in yet, but USDT looked stable • He met his friend through his son; he was a builder he had not seen for months that had just mentioned crypto to him nothing more • The crypto addresses he was sending to, were all his and no one was helping him he was doing it alone • He was using multiple wallets as they all seemed to have limits • No one had reached out to him online • The funds would only be held in his own wallet while he decided what to do with them • He had not downloaded screensharing software As Mr W had painted a picture of him sending funds as part of an investment he was reasonably provided with clear warnings associated with a cryptocurrency investment scam. Mr W confirmed again he was doing it on his own and just feeling his way through. Revolut then discussed the first international payment Mr W made. Mr W had already sent

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false documents to Revolut using its chat facility. Mr W confirmed: • He was making payments in relation to a house he was building, to a company providing goods to him • He had found the company online having carried out his own online search Another call took place when Mr W made withdrawal 8. Revolut explained there was a high risk associated with the payments he was making. The transaction pattern matched with that of other customers that had been scammed. Mr W confirmed: • He always answered questions honestly and was never dishonest • He had previously been scammed but the payment was nothing to do with what he was doing now • He had been learning online researching and wanted to try cryptocurrency • He had not installed any remote access software • He had started investing by searching himself online • He was frustrated with Revolut intervening • Bitcoin seemed to be the biggest one so thought he would give it a try • He had complete control • He had seen previous warnings and was aware he would lose his money if it was a scam It’s clear from all the information available that Mr W was not giving honest information when making payments and exchanges in relation to the scam that was taking place. Providing incorrect information would and did make it difficult for Revolut to uncover the scam that was taking place. While I think Revolut could have intervened further than it did, I don’t have enough to say that Mr W would have provided any more honest answers to its questions or taken notice of any warnings that would have been provided to him. So, with everything considered, I don’t think Revolut missed an opportunity to prevent the scam, and it is not responsible for Mr W’s loss. My final decision I don’t uphold this complaint. Under the rules of the Financial Ombudsman Service, I’m required to ask Mr W to accept or reject my decision before 28 April 2026. Terry Woodham Ombudsman

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