Revolut Ltd · DRN-5948140

The complaint Miss M complains that Revolut Ltd (Revolut) won’t refund money she lost when she was the victim of a scam. What happened The background to this complaint is well known to both parties, so I won’t repeat everything here. In summary, Miss M fell victim to a task-based job scam in June 2025. She was required to complete tasks in exchange for commission. Miss M saw an advertisement on social media promoting a job opportunity. She began discussing the role with one of the recruiters, (who I will refer to as “the scammer”). She was also added to a group chat with other “employees”. The messages on this group chat made her think this was a real opportunity. She was also paid some commission for completing some work which also made her think the role was legitimate. Miss M advised she was offered extra tasks which involved small investments. As a result, she transferred funds from her bank account, (with a firm I will refer to as “B”) to Revolut. She then sent the funds to cryptocurrency providers before sending all the funds into the control of the scammers. She also sent payments from her account with B. Miss M was expecting a payment from the scammers, but they told her that her credit score was too low to receive it. She was advised to transfer further funds. She realised she had been scammed shortly after this. Miss M lost around £4,700 from her Revolut account as a result of the scam. Miss M raised a complaint with Revolut. It didn’t think it had done anything wrong by allowing the payments to go through. So, Miss M brought her complaint to our service. Our Investigator looked into the complaint but didn’t uphold it. Our Investigator explained that Revolut had intervened on some of the transactions and provided warnings, but Miss M had provided inaccurate information about the payments. The Investigator also explained that Miss M was being heavily guided by the scammers to ensure all her payments were successfully processed. And that B had provided a number of warnings highlighting the role was a scam, but Miss M chose to transfer the funds to Revolut, and then on to the scam to avoid them being blocked. So, taking all the circumstances in to account he didn’t think Revolut could have prevented the losses suffered. Miss M didn’t agree, so her complaint has been passed to me for review and 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 Miss M has been the victim of a scam and lost money as a result of it. And I don’t underestimate the impact this has had on her. But while I know this will come as a

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disappointment to Miss M, for similar reasons as our Investigator, I don’t think Revolut has acted unfairly. I’ll explain why. I’m aware that I’ve summarised this complaint briefly, in less detail than has been provided, and in my own words. No discourtesy is intended by this. Instead, I’ve focussed on what I think is the heart of the matter here. If there’s something I have not mentioned, it isn’t because I have ignored it. I haven’t. I’m satisfied that I don’t need to comment on every individual point or argument to be able to reach what I think is the right outcome. Our rules allow me to do this. This simply reflects the informal nature of our service as a free alternative to the courts. I’ve thought about the Contingent Reimbursement Model Code (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. Miss M has also referred to the mandatory reimbursement scheme introduced by the Payment Systems Regulator which came into force in October 2024; however this scheme doesn’t cover payments sent to an account held by the customer. I’ve therefore considered whether Revolut should reimburse Miss M under any of its other obligations. In broad terms, the starting position in law is that a firm is expected to process payments and withdrawals that a customer authorises it to make. It isn’t disputed that Miss M authorised the payments from her Revolut account. Therefore, under the Payment Services Regulations 2017 and the terms of her account, Revolut is expected to process Miss M’s payments, and she is presumed liable for the loss in the first instance. But in some situations, it might be appropriate for Revolut to take a closer look at the circumstances of the payments – for example, if it ought to be alert to a fraud risk, because the transactions were unusual, or looked out of character or suspicious. And if so, it should have intervened, for example, by contacting the customer directly, before releasing the payments. This is to help protect customers from the possibility of financial harm from fraud. But I’d expect any intervention to be proportionate to the circumstances of the payment. Revolut recognised that some of the payments Miss M was making were high risk and provided her with advice and warnings to try and protect her from being scammed. It highlighted that to continue it needed to ask her some questions. Miss M responded to confirm the funds she was transferring were going to an account she controlled, that she had researched the company she was dealing with and they were regulated by the Financial Conduct Authority. On one of the payments she also confirmed she discovered the opportunity through a friend or family member. It’s clear that some of the information provided to Revolut wasn’t accurate. Revolut highlighted a number of cryptocurrency warnings detailing she could be falling for a scam. But the messages from the scammers confirm she was receiving guidance on how to answer Revolut’s questions so I think it would have been difficult for Revolut to identify she was falling victim to a scam based on her responses. It’s also clear that Miss M trusted what she was being told by the scammers and that she was under their spell so I don’t think further intervention from Revolut, regardless of how bespoke or tailored its questioning may have been, would have made a difference. I say this because B highlighted she was falling for a job scam in several phone calls it had with her, but Miss M continued sending payments through Revolut despite these warnings. B explained the reviews on the company confirmed it was a scam. It highlighted that it saw the type of scam Miss M was falling for every day. It provided context on why it was a scam by using specific scenarios. For example, it made it clear that scammers tend to provide small returns to a customer to build their confidence in the investment before asking them to

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transfer larger amounts of money over – these circumstances were relevant to Miss M. It also explained that she would lose her funds if she transferred them out of her cryptocurrency account and into the control of the scammer – which Miss M was doing. The responses from Miss M suggested she understood why this was a scam. But despite B raising these concerns it seems Miss M was determined to continue with the investment. I’m satisfied that B gave sufficient warnings highlighting the risks of investing and that Miss M understood the implications if she continued sending the payments. But unfortunately, Miss M chose to ignore warnings signs and explicit advice that she was being scammed. So, in the circumstances, even if Revolut had provided further warnings, I don’t think it would have been able to prevent the scam. I believe that Miss M was determined to send the funds despite being aware of the risks. And so it wouldn’t be fair to hold Revolut liable to refund her losses. I have noted the comments Miss M has made regarding Revolut’s obligations following the introduction of the Consumer Duty. But I’m not persuaded this changes the outcome here. While Revolut is expected to avoid causing her foreseeable harm, I’m not persuaded its actions were the main cause of the harm she has said she suffered. And as explained above I don’t think further intervention from Revolut would have prevented Miss M’s losses. Miss M has described herself as vulnerable. She’s shared details around these vulnerabilities with our service. Miss M believes that Revolut have a responsibility to identify potential vulnerabilities and that it should have taken them into account. While Revolut should be on the lookout for customer vulnerabilities, it can only act on those it was aware of or that were apparent when Miss M made the transfers. Here it wasn’t made aware of any vulnerabilities, and I can’t say that it should have made any special adjustments for her at the time the transactions were made. I have considered whether Revolut could have done anything to recover Miss M’s payments once the scam was uncovered. Revolut attempted recovery but, in the circumstances, I don’t think this would have made a difference. Miss M has confirmed she moved the cryptocurrency into the control of the scammer, so recovery would likely have failed. I’m sorry to hear Miss M suffered a financial loss as a result of what happened and the impact the loss has had on her. But it would only be fair for me to direct Revolut to refund her loss if I thought it was 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 it to do anything further. My final decision My final decision is that I’m not upholding Miss M’s complaint. Under the rules of the Financial Ombudsman Service, I’m required to ask Miss M to accept or reject my decision before 27 April 2026. Aleya Khanom Ombudsman

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