Monzo Bank Ltd · DRN-6262572

The complaint Miss C complains that Monzo Bank Ltd (“Monzo”) won’t reimburse funds she lost as part of a scam. What happened In July 2025, Miss C received a text message which contained details for a job opportunity. Miss C registered her interest, and continued to discuss the opportunity with the scammers via a messaging app. Satisfied with what she’d seen, Miss C made three payments totalling £1,290, on 17 July 2025, as part of the job opportunity. Shortly after the final payment, Miss C realised she’d been the victim of a scam. Miss C contacted Monzo to request they reimburse the funds she lost as part of the scam. Monzo looked into the matter and reimbursed the first payment Miss C made as part of the scam. But, Monzo declined to reimburse the final two payments Miss C made as they were international payments and were therefore not covered by the relevant reimbursement rules. Unhappy with this response, Miss C referred her complaint to our service. Our investigator looked into Miss C’s complaint but did not uphold it. The investigator felt that Monzo couldn’t have identified the scam Miss C was falling victim to at the time of the payments, so they couldn’t have prevented the scam. The investigator also felt that Monzo did what they could’ve in order to recover her funds and that they weren’t liable to reimburse Miss C’s loss. Miss C disagreed with the investigator’s findings and asked for an ombudsman to review the complaint. As the complaint couldn’t be resolved by the investigator it was passed to me for a decision. What I provisionally decided – and why In my provisional decision I said: I’ve considered all the available evidence and arguments to decide what’s fair and reasonable in the circumstances of this complaint. Miss C has provided detailed submissions to our service in relation to this complaint. In keeping with our role as an informal dispute resolution service, I will focus here on the points I find to be material to the outcome of Miss C’s complaint. This is not meant to be a discourtesy to Miss C and I want to assure her I have considered everything he’s submitted carefully. In deciding what’s fair and reasonable in all the circumstances of a complaint, I’m required to take into account relevant: law and regulations; regulators’ rules, guidance and standards;

-- 1 of 4 --

codes of practice; and, where appropriate, what I consider to be good industry practice at the time. In broad terms, the starting position at law is that a bank such as Monzo is expected to process payments and withdrawals that a customer authorises it to make, in accordance with the Payment Services Regulations (in this case the 2017 regulations) and the terms and conditions of the customer’s account. Here it’s not in dispute that the payments were authorised, so the starting position is that Monzo isn’t liable for the transactions. There are, however, some situations where we believe that businesses, taking into account relevant rules, codes and best practice standards, shouldn’t have taken their customer’s authorisation instruction at ‘face value’ – or should have looked at the wider circumstances surrounding the transaction before making the payment. Monzo also has a duty to exercise reasonable skill and care, pay due regard to the interest of its customers and to follow good industry practice to keep customer’s accounts safe. This includes identifying vulnerable consumers who may be particularly susceptible to scams and looking out for payments which might indicate the consumer is at risk of financial harm. Taking these things into account, I need to decide whether Monzo acted fairly and reasonably in its dealings with Miss C. From 7 October 2024, Payment Services Providers in the UK are bound by the Faster Payments Scheme (FPS) reimbursement rules. Under these rules, most victims of authorised push payment (APP) scams should be reimbursed. But, these rules do not cover international payments. As the payments Miss C is disputing are international payments, I’m satisfied that the above rules are not applicable. I’ve considered whether there is any other reason, outside of the ASR rules, that Monzo may have been reasonably expected to have prevented Miss C’s loss at the time the payments were made. Having reviewed the previous genuine transactions from Miss C’s account, I’m not persuaded that the payments she made were particularly unusual or out of character whereby I would’ve expected Monzo to intervene. Though the sum of the payments is significant to Miss C, I don’t consider them to have been substantial enough to have presented a risk to Monzo that she may be at risk of fraud or financial harm. I say this because, having reviewed the previous transactions from Miss C’s account, they are not of an amount which represent a clear or suspicious deviation from her typical spending. I can see that Miss C has made transactions from her account for similar amounts to that of the individual scam payments, as well as the overall sum of them. I can also see that Miss C made an international payment around six weeks prior to the scam payments, which shows that it wasn’t novel for an international payment to be made from her account at the time of the scam. The first payment Miss C made as part of the scam was to a new payee whose account was based in the UK. The next two payments were made to another new payee, whose account was based overseas. These last two payments were made around 40 minutes apart and so I

-- 2 of 4 --

don’t think the speed in which they were alerted Monzo to the possibility that Miss C was falling victim to a scam. Because of this, I’m not persuaded that Monzo ought to have intervened and questioned Miss C regarding the payments prior to their release or that they ought to have prevented her financial loss at the time the payments were being made. I’ve considered whether Monzo did what they should have when they were made aware that Miss C had fallen victim to a scam. I can see that Monzo contacted the relevant beneficiary in an attempt to recover Miss C’s funds on 20 August 2025. Unfortunately, these attempts were unsuccessful as Miss C’s funds were no longer in the account. Since then, it appears as though there has been some miscommunication between the parties, with Monzo advising Miss C that they aren’t able to contact the beneficiary and instead directing Miss C to contact them herself. As stated above, Monzo had in fact contacted the beneficiary bank to recover Miss C’s, so referring her to them was incorrect and had added considerably to the trouble and upset she has experienced. It’s also important to note that Monzo referred Miss C to the beneficiary bank on numerous occasions over a protracted period, even though they could’ve explained that they’d already taken steps to recover her funds. Having reviewed the correspondence between the parties and Miss C’s testimony, it’s clear that this added significant distress on top of an already difficult situation. Because of that, I believe that Monzo ought to pay Miss C £150 in recognition of the trouble and upset caused. Overall, I’m not persuaded Monzo should reimburse Miss C’s loss as I don’t believe they ought to have prevented the payments at the time they were made or that they could’ve recovered Miss C’s funds when they were made aware of the scam. I do, however, believe that Monzo ought to pay £150 to Miss C in recognition of the trouble and upset caused. I appreciate this will be disappointing to Miss C, given the impact this situation has had on her, but I’m unable to say that Monzo are liable to reimburse her loss in full. My provisional decision My provisional decision was that I intended to uphold this complaint, in part, against Monzo Bank Ltd, as set out above. Responses to my provisional decision Monzo responded to say that they accept my provisional decision and had nothing further to add. Under the Dispute Resolution Rules (found in the Financial Conduct Authority’s Handbook), DISP 3.5.15 says if a complainant (Miss C) fails to comply with a time limit, the ombudsman may proceed with the consideration of the complaint. As I’ve received a response from Monzo, and the deadline for Miss C to respond to my provisional decision has expired, I’m going to proceed with issuing my final decision. What I’ve decided – and why I’ve considered all the available evidence and arguments to decide what’s fair and reasonable

-- 3 of 4 --

in the circumstances of this complaint. As I’ve received no additional arguments or evidence following my provisional decision, I see no reason to reach a different outcome in my final decision. Because of that, I’m satisfied that Monzo ought to pay Miss C £150 in recognition of the trouble and upset caused, for the reasons explained in my provisional decision. Putting things right To put things right Monzo should pay Miss C £150. My final decision My final decision is that I uphold this complaint, in part, against Monzo Bank Ltd. Under the rules of the Financial Ombudsman Service, I’m required to ask Miss C to accept or reject my decision before 28 April 2026. Billy Wyatt Ombudsman

-- 4 of 4 --