Plus500UK Ltd · DRN-5509253

The complaint Mrs N’s complaint is about the suspension and closure, by Plus500UK Ltd (‘Plus500’), of her trading account in 2024. She says the suspension and closure (including the processes for both) were unfair, and she seeks redress for financial loss (around 13,000 Euros at the time of the closure and around 70,000 Euros since) that she says resulted from both. What happened The account was opened in 2019. Mrs N describes how, initially, her trading was broadly unsuccessfully, until she eventually found a favourable strategy that transformed her trading outcomes. She believes this change in fortunes, and subsequent consistency in her successful trading outcomes, attracted Plus500’s undue attention, in the form of her account being monitored closely and unfairly. She refers to unprompted requests she received from Plus500 in August 2024 for evidence of her source of funds and source of income, and for an explanation of withdrawals she had initiated then cancelled a number of times. Mrs N says these enquiries were unwarranted and unclear (in terms of what, specifically, Plus500 wanted from her), and that she addressed them as best as she could. The account was suspended because of Plus500’s dissatisfaction with her responses, then it was closed. A chronology of key events, related to both, can be summarised as follows – • On 23 August Plus500 asked Mrs N for “… a valid document to verify the source of your recent funds. This should be a recent bank statement or savings account statement …” and “… a valid document to support your recent deposits. This can be a recent statement from a personal bank or savings account … or any similar document which demonstrates that you own sufficient funds to be able to trade at your current level”. It explained that the requests were part of its ongoing account monitoring obligations. • Plus500’s records include an entry dated 3 September confirming that online banking screenshots had been received from Mrs N, and that they were deemed insufficient to meet the requests. On 4 September her account was suspended/restricted, no new trades could be opened in it. The records show that on 5 September it received further screenshots from her which were also deemed insufficient to meet the requests. • On 6 September Plus500 wrote to Mrs N. It said the documents she had provided did not suffice and were not detailed enough “… to verify the source of [her] recent funds or support [her] recent deposits”, and it instructed her as follows – “… to proceed, you have to provide us with a recent payslip or P60 which clearly shows how you obtained the funds used for investing”. It also asked her for an explanation of the many withdrawal cancellations it had identified in her account and an updated annual deposit limit figure, and both requests were made on a to proceed further basis. • Plus500’s records show that Mrs N replied on the same date. In her response, she

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expressed concerns about its information requests, she said funds deposited or withdrawn from her account depended on her trading strategies and market fluctuations (whereby she sometimes considered withdrawals in order to lower her market exposure, then decided against doing so, hence the cancellations), she insisted that the documents she had provided met the initial information requests and she expressed concern about the account suspension (she referred to the potential for it to result in financial loss and said she regards Plus500 responsible for that). • On September 10 Plus500 gave Mrs N 14 days’ notice of termination of her account. She replied on the same date to question its reason. On 11 September it responded to say the terms agreed for the account entitled it to terminate the account with or without cause, so long as written notice was provided. She replied further on 13 September to say she disagreed with the termination decision. • On 24 September she asked for an extension of time in her account, for two years, in order to avoid a financial loss of 13,000 to 20,000 Euros in trades that were open at the time. Plus500 did not grant her request. It sent her a reminder that her account was due for closure at 5pm UK time on this date, and that any open trades within it at this deadline will be closed. Its records show that some trades remained opened at the deadline and were to be subsequently closed. One of our investigators looked into the complaint and concluded that it should not be upheld. In short, he was satisfied, with reasons (which he explained), that Plus500 had reasonable grounds in the terms agreed for the account and in the facts of the case to take the steps it took. Mrs N disagreed with this outcome. The investigator addressed her comments and elaborated on his findings, but he was not persuaded to change his conclusion. She asked for an Ombudsman’s decision, and she made final submissions for the Ombudsman’s attention. In the main, Mrs N’s final submissions make the following arguments – “The initial email from Plus500 … merged two distinct regulatory concepts (“source of funds” and “support for deposits”) without clearly defining either or explaining what was needed, or by when. There was no secure portal, no deadline, and no warning of the consequences. The vague and informal language led me to question the authenticity of the email. I responded cautiously, and I believe this was later misinterpreted as non-cooperation.” “Plus500 restricted my account before I had a meaningful chance to respond or adjust my trades.” “Forcing account closure within 14 days (especially when already restricted) fundamentally undermined my trading plan and financial rights as a retail investor.” “At the time of closure, I experienced a direct financial loss of approximately €13,000– €15,000, due to my inability to manage or hold open trades. These were part of a long-term investment strategy that could have brought substantial returns had I not been forced to exit prematurely.” “Following the closure, Plus500 deleted my entire account, including all records.” “… I respectfully disagree with the investigator’s conclusion. Their view did not fully address:

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• The confusing and unprofessional nature of Plus500’s communication, • The disproportionate effect of the account restriction and sudden closure, • The deletion of my data, • And the financial and emotional impact of these actions.” 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, I have reached the same conclusions as those expressed by the investigator. I do not uphold Mrs N’s complaint. On balance, I find that Plus500 had reasonable grounds, in the terms agreed for her account and in the circumstances of her case, to take the steps it took in its information requests, account suspension and then account termination. I deal with the agreed terms first, as I consider they provide helpful context. I quote the following from the account’s User Agreement (applicable in 2024) – Section 5.3 includes – “We may carry out various checks (including but not limited to verification of identity, fraud prevention checks and checks into your current and past investment activity) from time to time as we deem appropriate.” Section 5.4 includes – “We reserve the right to periodically request additional and up-to-date documentation and/or data from you, in order to ensure that our records are up to date. This does not negate your responsibility to ensure that you advise us, in a timely manner, of all changes to your personal situation.” The above support the information requests Plus500 put to Mrs N. With regards to the account suspension/restriction, and then its termination, the User Agreement provided as follows – “22.3. The Client Agreement may be terminated by either party at any time …” “22.6. We shall be entitled to immediately terminate the Client Agreement, with or without cause, acting reasonably by providing you with written notice. Any open positions should be closed by you as soon as reasonably practicable and in any event no longer than 14 days after we give Notice, after which we reserve the right to close such Transactions on your behalf, at the last available price, before permanently closing your Trading Account. 22.7. You unconditionally agree that the Company has the right to close or suspend your account without notice and with immediate effect if any of the following events occur: … Failure to provide information required by the Company in a timely manner in relation to any verification process applied by the Company to your Registration Data.” I am satisfied that the above gave Plus500 the right to suspend Mrs N’s account where there was a failure to meet its requirement for information associated with its verification processes, gave both parties the right to terminate the account at any time, and gave Plus500 the right to do so, with or without cause, after providing up to 14 days’ notice. I now deal with the circumstances in Mrs N’s case. Plus500 had four lines of enquiry, for which information was required and requested from her.

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As it explained on 23 August it needed – “… a valid document to verify the source of … recent funds. This should be a recent bank statement or savings account statement …”; and “… a valid document to support … recent deposits. This can be a recent statement from a personal bank or savings account … or any similar document …”. As it then explained, on 6 September, another option for Mrs N to meet these requirements was for her to provide “… a recent payslip or P60 which clearly shows how [she] obtained the funds used for investing”. Plus500’s third and fourth lines of enquiry were for an explanation of the withdrawal cancellations it had identified in her account and for an updated annual deposit limit figure from her. On balance, I consider that these four requirements were reasonable in the context of Plus500 discharging its ongoing regulatory account monitoring and verification related obligations. I do not accept that any of them were unclear, especially not after the 6 September additional clarification (and additional option) that was given for the first two. Plus500 needed evidence of the ‘source’ of recent funds in the account, and evidence to support recent deposits into the account at the time. These were arguably self-explanatory, in the sense that they conveyed, overall, a need to show where money used for recent funding in the account had originated from. Examples of the sort of documentation required were also given – bank statements, savings account statements or any similar document. This was further simplified by Plus500 giving Mrs N the option to satisfy some of the requirements by simply providing a recent payslip or P60. She did not provide a payslip or P60. The online banking screenshot she initially shared did not depict a ‘source’ of funds (as in, where her money had originated from), but it does appear to have shown a 1,000 Euros payment, on 27 August, from her bank account into her Plus500 account. The additional document she provided presented information about her savings account – a balance figure of 9,000 Euros and what appear to be withdrawal and deposit transactions between 9 July and 22 August. Plus500 says it found these documents to be vague and insufficient. I can see both sides of this argument. On the one hand, I can understand why Mrs N could have felt that she had showed her savings account as being source of her funds and that she had evidenced the funding payment on 27 August from her bank account to her trading account. However, on the other hand, Plus500 wanted more than what the documents showed, hence its request, on 6 September, for a recent payslip or P60. My understanding is that its aim was to verify where Mrs N’s money had originated from, so presentation of the savings account balance was one thing, but evidence of how that balance had been created was another. It was more interested in the latter than in the former, hence the request for evidence of her earnings (the payslip/P60). In this context, I can see why the account was suspended, pending resolution of the enquiries. As I established above, there was contractual provision for an account suspension in such circumstances (where information required in a verification process is outstanding). In this case, a verification of source of funds enquiry remained unsettled, so it is not difficult to see why the suspension provision was applied. Mrs N did not like the intrusiveness she perceived in these enquiries. That is understandable, to an extent, and I can see that Plus500 was sensitive to this. Its initial enquiry included – “We understand that this may feel intrusive, but as you know, Plus500UK has a regulatory obligation to ensure that the information we hold on our clients is accurate and up to date”. She ought reasonably to have taken this explanation on board and maintained her cooperation with its requests, knowing that it did not seek to be unduly

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intrusive but instead it sought to discharge a regulatory obligation. Unfortunately, she did not maintain such cooperation. I summarised her response to the 6 September request earlier. It does not appear that she provided the payslip or P60 that was requested/required. Instead, she challenged Plus500’s approach. Her response addressed Plus500’s third line of enquiry (about the cancelled withdrawals), but not the fourth (about an updated annual deposit limit figure). Overall, as far as Plus500 could see, Mrs N had not evidenced source of funds, and she had not addressed the updated annual deposit limit figure enquiry. Though it is not explicitly clear, it also looks like it might not have been satisfied with her response to the cancelled withdrawals issue. Its decision to terminate the account is not reasoned. As I established above, there was no contractual requirement for it to give a reason. However, the decision was made within the monitoring/verification exercise, so I can understand why Mrs N considers that both were connected. She had not properly addressed the requirements in that exercise, so that might or might not have influenced Plus500’s decision. The points remain that it did not have to give a reason to terminate the account, and it gave 14 days’ notice of the termination, as contractually required. Furthermore, I have not seen grounds on which to say it took this step unreasonably or unfairly, in the circumstances. Even if the monitoring/verification exercise was an influencing factor, it is a fact that there were problems in the exercise and it was not successfully completed, so these could have served as arguably good reasons to consider a termination of the account. The decision to terminate her account implicitly and expressly meant Plus500 no longer wanted Mrs N to have and use a Plus500 trading account. Therefore, a two years extension of time, as she requested, would not have been viable, the same would have applied to any arrangement that allowed her to continue trading (in any form) in the account, and termination of her access to data in the account was to be expected in the context of a termination of the account itself. I understand her unhappiness about the effects on her open trades at the time, but she had ample time and opportunity – beginning from the account suspension on 4 September, continuing to the 10 September termination notice, continuing further to the end of the 14 days’ notice period on 24 September, and amounting to a total of 20 days – to mitigate those effects. In these circumstances, I am not persuaded that Plus500 is responsible for any loss she claims. My final decision For all the reasons given above, I do not uphold Mrs N’s complaint. Under the rules of the Financial Ombudsman Service, I’m required to ask to accept or reject my decision before 27 April 2026. Roy Kuku Ombudsman

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