National Westminster Bank Public Limited Company · DRN-6238358

The complaint Mr S is being represented by solicitors. He’s complaining about National Westminster Bank Public Limited Company because it declined to refund money he lost as a result of fraud. What happened Sadly, Mr S fell victim to a cruel job scam after he was contacted about what he believed to be a legitimate job opportunity. He was required to carry out sets of tasks that he needed to pay to access and expected to receive commission for completing. He says he was added to a chat group with other workers and set up with an account on a platform that appeared to show his earnings increasing as he completed sets of tasks, all of which helped convince him he was working for a legitimate company. In September 2025, Mr S used his NatWest account to make the following payments to the scam: No. Date Amount £ Payee Method 1 17 Sep 70 Crypto exchange Card 2 19 Sep 100 Crypto exchange Transfer 3 19 Sep 50 Crypto exchange Transfer 4 20 Sep 30 Crypto exchange Transfer 5 21 Sep 75 Crypto exchange Transfer 6 21 Sep 50 Crypto exchange Transfer 7 22 Sep 200 Crypto exchange Transfer 8 23 Sep 900 Money transfer service Transfer 9 23 Sep 1,802.99 Money transfer service Transfer 10 24 Sep 1,802.99 Money transfer service Transfer 11 24 Sep 1,802.99 Money transfer service Transfer 12 24 Sep 1,802.99 Money transfer service Transfer 13 25 Sep 1,502.99 Money transfer service Transfer 14 26 Sep 1,102.99 Money transfer service Transfer Payments 1 to 7 went to a cryptocurrency account in Mr S’s own name, from where the currency purchased was transferred to the scammers. Payments 8 to 14 were sent to the scammers via an account in his own name with the money transfer service. NatWest account statements show Mr S received five payments from the cryptocurrency exchange totalling £462.81 between 17 and 21 September. I understand the rest of the money was lost to the scam. On 25 September, Mr S made an additional payment of £800 using a different money transfer service. I haven’t included this payment above as statements show this was returned to the account immediately. My provisional decision

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After the complaint was referred to me, I issued my provisional decision setting out why I thought it should be partly upheld. My reasons were as follows: There’s no dispute that Mr S authorised these payments. In broad terms, the starting position at law is that a bank is expected to process payments a customer authorises it to make, in accordance with the Payment Services Regulations and the terms and conditions of their account. In this context, ‘authorised’ essentially means the customer gave the business an instruction to make a payment from their account. In other words, they knew that money was leaving their account, irrespective of where that money actually went. This notwithstanding, there are some situations where we believe a business, taking into account relevant rules, codes and best practice standards, shouldn’t have taken its customer’s authorisation instruction at ‘face value’ – or should have looked at the wider circumstances surrounding the transaction before making the payment. NatWest also has a duty to exercise reasonable skill and care, pay due regard to the interests of its customers and to follow good industry practice to keep customers’ 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 points into account, I need to decide whether NatWest acted fairly and reasonably in its dealings with Mr S. Should NatWest have recognised that Mr S was at risk of financial harm from fraud? I must take into account that many similar payment instructions NatWest receives will be entirely legitimate. I also need to consider its responsibility to make payments promptly. Having considered what NatWest knew about payments 1 to 7 at the time, I’m not persuaded it ought to have been particularly concerned. While it would have known they went to cryptocurrency and that this meant there was a higher risk they were associated with fraud, the amounts involved were low. The amounts involved in payments 8 to 10 were higher but they were to a new payee not directly associated with cryptocurrency. In the circumstances, I don’t think there were sufficient grounds for NatWest to think at the time that payments 1 to 10 indicated Mr S was at risk of harm from fraud and I can’t reasonably say it was at fault for processing them in line with his instructions. By the time of payment 11, however, I think NatWest should have identified Mr S may be at risk of harm from fraud. This was his second large transfer for the same amount on the same day and followed a transfer for the same amount again the previous day. Further, these transfers followed a series of seven payments, albeit for low amounts, to cryptocurrency in the preceding week. It’s my view that this is the point at which a pattern of multiple, rapid and increasing payments consistent with many types of known scams had begun to emerge and that NatWest should have intervened in the payment process. What did NatWest do to warn Mr S? NatWest has confirmed that none of the payments were flagged by its systems for further intervention.

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What kind of intervention should NatWest have carried out before processing payment 11? Having thought carefully about the risks this payment presented, I think a proportionate response to those risks would have been for NatWest to have attempted to establish the circumstances surrounding the payment before allowing it to Mr S’s account. I think it should have done this by, for example, speaking to him on the phone to discuss the payment further. If NatWest had intervened as I’ve described, would that have prevented the losses Mr S suffered from payment 11? During a scam intervention call, I would have expected the bank’s agent to have asked Mr S about the purpose of the payments he was making. The history of his communications with the scammers show that on 20 September, he went into some detail about how a bank’s security checks could be avoided. If he’d spoken to the bank on that day I’m not convinced he’d have been open about what he was doing. But by 23 September – the day before payment 11, the chat history appears to show Mr S was having serious doubts about the scheme. He said to the scammers on that day that he was ‘sick and tired’ and had made ‘the biggest mistake of my life’ as ‘all your company is doing is extracting money from me’ and that he ‘couldn’t sleep’ because of the money he’d ‘lost’. He also appears to have been doubting the legitimacy of the scheme and asked ‘please be honest is this how your company is cheating people’. In view of his apparent mood by the time of payment 11, I think Mr S would have responded much more favourably to a conversation with one of the bank’s agents. And if he understood that the purpose of the call was to protect him from possible fraud, I think it’s most likely he’d have answered appropriate probing questions about the payments honestly given the doubts he was clearly already having about the scheme. If Mr S had explained that he was paying money for online work, I’d have expected the bank’s agent to have identified this was likely to be a scam, explained this and provided warnings setting out common features of job scams, and advised him against making further payments. Even if Mr S wouldn’t have explained what the payments were for, which I think is less likely in the circumstances, I think the bank’s agent should have recognised that the pattern of payments was consistent with either an investment or a job scam. They would then have been in a position to provide a warning setting out common features of these types of scam. Common features of job scams that could have been outlined include that victims are often approached by someone they don’t know, offered online work that requires them to complete sets of tasks, promised very high earnings compared to the time they’ll spend working, required to pay to access tasks (often in cryptocurrency), and that scammers often have professional looking websites and platforms, will pay out small amounts at the outset to convince victims the scam is legitimate, and often ask victims to pay fees and taxes when they try to withdraw their money. If the bank had provided tailored warnings covering common features of job scams, I think Mr S would have recognised many of these features in his own situation and that this would have resonated with him. On balance, particularly in view of the serious concerns he’d already expressed in conversation with the scammers only the previous day, I think the most likely outcome is that he’d have recognised he was being scammed and decided not to go ahead with the payment.

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I think it follows that if the scam had been uncovered at the point of payment 11, payments 12 to 14 would also have been prevented. Is it fair and reasonable for NatWest to be held responsible for Mr S’s loss? I have taken into account that Mr S remained in control of his money after making the payments from NatWest. It wasn’t lost until he took further steps. But NatWest should still have recognised he was at risk of harm from fraud, made further enquiries about payment 11 and ultimately prevented his loss from that point. I think NatWest can fairly be held responsible for any loss in these circumstances. While I have considered all the facts of the case, including the role of other financial institutions involved, Mr S has chosen not to pursue a complaint about any other business and I can’t compel him to do so. Further, I don’t think it would be fair to reduce his compensation because he’s only complained about one business, as I consider that NatWest should have prevented the loss. Should Mr S bear any responsibility for his losses? I’ve considered the evidence carefully to decide what’s fair and reasonable in the circumstances. While I accept Mr S believed these payments were being made in connection with a legitimate job opportunity, I’m not persuaded that belief was a reasonable one. Firstly, I’ve seen no evidence there was any formalisation of the arrangement between Mr S and the employer – for example, a written contract or other clear setting out of the terms of employment. Also the earnings advertised by the scammers were extremely high for the amount of work that was said to be required and I think he should reasonably have questioned whether this was too good to be true. In addition, the arrangement was very different to the normal employer- employee relationship. In most circumstances, people expect to be paid by their employer, rather than the other way around. Finally, I note that Mr S was having serious doubts about the scheme from at least 23 September but continued to send money. In the circumstances, I think Mr S should have proceeded with great caution. If he’d carried out any further research, for example online searches, I think he’d have discovered his circumstances were similar to those commonly associated with many job scams. Overall, I think it’s fair and reasonable for NatWest to make a 50% deduction from the redress payable. Recovery of funds As the payments were sent to the scammers via accounts in his own name Mr S isn’t eligible for any refund under the industry’s reimbursement scheme for authorised push payment (APP) fraud. But I have looked at whether NatWest could or should have done more to try and recover his losses once it was aware the payments were the result of fraud. The payments were sent via legitimate accounts in Mr S’s own name and NatWest could only try to recover money from those accounts. By the time the scam was reported, it appears the money had already been moved on. If not, anything was left would still have been available for him to access.

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As the first payment was made by card, I’ve considered whether NatWest should have tried to recover the money through the chargeback scheme. But I’d only expect it to have raised a chargeback claim if it was likely to be successful and it doesn’t appear that would have been the case here. The money was paid to a legitimate cryptocurrency exchange and Mr S received the requested service, that of exchanging his money into cryptocurrency before sending it to the destination he supplied it with. Mr S’s disagreement is with the scammers, not the cryptocurrency exchange and it wouldn’t have been possible for NatWest to process a chargeback claim against the scammers as he didn’t pay them directly. In the circumstances, I don’t think anything that NatWest could have done differently would likely have led to these payments being successfully recovered. In conclusion For the reasons I’ve explained, I don’t think NatWest acted fairly and reasonably in its dealings with Mr S and I’m proposing to upholding this complaint in part. While I don’t think the bank acted incorrectly in processing payments 1 to 10 in line with his instructions, if it had carried out an appropriate intervention before payment 11 left his account, I’m satisfied payments 11 to 14 would have been prevented. The responses to my provisional decision Mr S’s representative confirmed his acceptance of my provisional decision and had nothing further to add. NatWest emphasised it’s not the point of loss in this case as the payments I’ve said should be refunded went via a money transfer service. As a result it’s unable to establish what activity took place after the money left the bank. It asked for confirmation that I’ve seen evidence this money was lost and that no recovery has taken place. 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. Having done so, my findings haven’t changed from those I set out previously. In response to NatWest’s comments: • I’m satisfied the extensive record of Mr S’s chat with the scammers shows he was the victim of a scam and that the money sent via the transfer service was routed to them. • In making his complaint, Mr S has said that no returns were received relating to the payments I’ve said should be refunded and that’s very plausible at this stage of the scam. In my experience, any money returned from a scam is usually received in the early stages to entice the victim to make further payments. I’m also unaware of any money being returned to his NatWest account and I would have expected the bank to provide details if it had been. • Mr S has also confirmed that no money has been recovered through other means and that he hasn’t complained to the money transfer service. On balance, I’m persuaded that the money sent in payments 11 to 14 was indeed lost to the scam.

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Putting things right The principal aim of any award I make must be to return Mr S to the position he’d now be in but for the errors or inappropriate actions of NatWest, while allowing for any responsibility he should reasonably bear. If the bank had carried out an appropriate intervention as I’ve described, I’m satisfied the scam would have been stopped and Mr S would have retained the money that was lost from payment 11 onwards. As outlined above, I’ve applied a 50% deduction to the amounts to be refunded in recognition of his own contribution to the loss. I can also see that Mr S received money back that he presumably understood to have been earnings from the work he’d completed. Given he was falling victim to a scam and the job wasn’t genuine, I don’t think this money should be attributed to any specific payment. Instead, I think it should be deducted from the amount lost by apportioning it proportionately across all of the payments made to the scam. This ensures that these credits are fairly distributed. To put things right NatWest should pay Mr S compensation of E + F, where: • A = £11,292.94, representing the total of payments 1 to 14 to the scam; • B = £462.81, representing the amount returned to him; • C = £10,830.13, representing the total loss to the scam (A - B); • D = 95.90%, representing the proportion of A that was lost to the scam (C divided by A); • E = a refund of 47.95% of each of payments 11 to 14, representing a 50% refund of the portion of these payments that were lost to the scam; and • F = simple interest on each amount being refunded in E - at the time-weighted average Bank of England base rate plus one percentage point - from the date of the corresponding payment to the date compensation is paid. Interest is intended to compensate Mr S for the period he was unable to use this money. I’ve used the above rate as the complaint was referred to us after 1 January 2026. HM Revenue & Customs (HMRC) requires NatWest to deduct tax from any interest. It must provide Mr S with a certificate showing how much tax has been deducted if he asks for one. I’m satisfied this represents a fair and reasonable settlement of this complaint. My final decision My final decision is that I partly uphold this complaint. Subject to his acceptance, National Westminster Bank Public Limited Company should now put things right as I’ve set out above. Under the rules of the Financial Ombudsman Service, I’m required to ask Mr S to accept or reject my decision before 16 April 2026. James Biles Ombudsman

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