Revolut Ltd · DRN-6188113

The complaint Miss H complains that Revolut Ltd (Revolut) failed to identify that she was gambling compulsively and they didn’t provide appropriate support when she raised this with them and requested help. What happened I issued a provisional decision on this complaint, inviting both parties to let me have any further comments. Below is a copy of what I provisionally decided and why. Miss H opened her account with Revolut in 2023 and used it for gambling transactions. Shortly after, she told Revolut via their chat that her phone was stolen and someone else had opened the account and made the payments. Revolut asked her to complete the verification process so they could investigate what she’d told them, but she didn’t proceed. After this, the account had a low level of spending until April 2025, when the gambling activity increased. Miss H contacted Revolut in late May 2025, requesting that they close the account. They told her how she can do this herself after clearing the balance and they asked for the reason for the closure request, but she didn’t respond. The gambling spending on the account continued until Miss H contacted Revolut in late July 2025. She complained that they failed to identify that she was gambling compulsively and they should have closed the account when she contacted them. Revolut responded to her complaint explaining that they can’t refund any transactions due to the chargeback guidelines, but they didn’t address the level of spending on the account or whether they should have closed it when Miss H got in touch. Miss H remained unhappy, so she referred the complaint to our service. While the complaint was with our service, Miss H had continued to gamble on the account and asked Revolut on multiple occasions to close the account to prevent her spending. However, they advised that this couldn’t be done as there were pending transactions which hadn’t cleared. Miss H eventually complained about this and Revolut again responded explaining why a chargeback wasn’t possible, but didn’t address the gambling activity or the requests to close the account. An Investigator reviewed the complaint and didn’t think that Revolut had made an error. They didn’t think that the activity on the account would have triggered a manual review, so they wouldn’t have known about the gambling activity until she raised it with them. They also thought that the closure requests were handled appropriately as Miss H hadn’t verified the account and there was a balance on the account that hadn’t been cleared. Miss H disagreed with this outcome as she thought Revolut should have done more to help her close the account after she had made them aware of her situation. She also thought the response wasn’t in line with other decisions she found on our website, as they had upheld the complaint and hers had similar circumstances. As such, the complaint has been referred to me for a final decision.

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In mid-December 2025, Miss H had been in touch to confirm that she was able to close the account and cease her gambling activity. This was also the point that she was notified about a gambling block that was available on the Revolut app and she enabled it straight away and stopped gambling. What I’ve provisionally 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 can see Miss H feels strongly that Revolut are responsible for allowing her continued gambling activity and while I’ve considered the points both parties have made in detail, I’ll comment on the points that I think are key to the outcome. Miss H referred to two previous decisions when she provided her reasons for disagreeing with the outcome. Each complaint is decided based on its own merits and the circumstances will always be different. I’ve reviewed the copies of the decisions provided and I’m satisfied that the circumstances are different. Particularly as they relate to a business’ actions after being notified of a problem with gambling, whereas Miss H thinks that Revolut should have identified the issue before she contacted them. In accordance with the Payment Services Regulations, Revolut is expected to process the payments and withdrawals that Miss H authorises it to make. Broadly, Miss H is entitled to spend her money as she chooses, and this includes making gambling transactions. Most banks don’t monitor accounts for gambling transactions, so a bank won’t ordinarily know its customer has a gambling problem unless the customer tells it, or if the account is manually reviewed for some other reason, such as if its customer has requested lending or shown clear signs of financial difficulty. When a customer makes their bank aware that they are gambling compulsively, the bank are expected to provide appropriate support. Which can include signposting to relevant organisations, explaining the spending tools they have available, and assessing whether the current process in place will cause further harm to the customer. This is particularly important as addiction is a sign of vulnerability which leads to compulsive behaviour and challenges in making the right decisions at the right time. Before Revolut were notified of Miss H’s gambling activity I can see that Miss H first made Revolut aware of her compulsive gambling in late July 2025. I’ve reviewed the way the account was being used prior to this and can see that it was being used almost solely for gambling. The account was regularly topped up when the balance was low, and large winnings were often sent to a separate account in Miss H’s name. The presence of gambling transactions doesn’t mean that someone is an addict or that the activity needs to change – which could be indicated by signs of financial difficulty. I’ve reviewed the spending and can’t see any signs that it was becoming unmanageable, so I’m satisfied that Revolut wouldn’t have known about Miss H’s gambling issues until she told them. Miss H contacted Revolut on two key occasions prior to July 2025. I think the first contact where the activity was reported as unauthorised was likely an attempt to recover some funds. Miss H didn’t verify her identity so Revolut couldn’t proceed to investigate her request. Similarly, when Miss H contacted Revolut in May 2025, she was given instructions to close the account but didn’t carry them out. As mentioned above, Revolut wouldn’t have been aware that Miss H was gambling compulsively on either of these occasions, so they wouldn’t

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have known if tailored support was required. Overall, I think they handled things reasonably prior to the point they were made aware of Miss H’s compulsive spending. After Revolut were notified of Miss H’s gambling activity In July 2025, Miss H made Revolut aware of her gambling addiction. She explained that they should have closed her account, and she asked for the payments she made to be refunded. Revolut responded explaining why a chargeback wouldn’t be successful, but they didn’t provide her with any information about the blocks and tools that she had access to or where she could go to get support. After this her gambling activity paused and restarted in October 2025 and increased consistently until the account was closed in December 2025. I can see that Miss H contacted Revolut on multiple occasions during this period asking them to close her account, but she received an automated response that she couldn’t do this until the balance was cleared and there were no pending transactions. This response didn’t take into account her circumstances or that she had told Revolut that she was struggling to manage spending on the account due to her addiction. Revolut also told our service that this couldn’t be done until Miss H had verified her account. But I can see that Miss H verified her identity shortly after complaining and no further requests for verification were made by Revolut – so I don’t think a verification issue was the reason for the account remaining open. The account couldn’t be closed due to Revolut’s policy on pending transactions – which I don’t disagree with. However, it’s clear that a customer that spends compulsively can end up in a cycle where there are always pending transactions on the account, resulting in an inability to close the account to prevent spending. I’d expect Revolut to mitigate this risk by ensuring that they make customers aware of the spending controls that they have available. Which would have been a reasonable response to someone who had expressly told them they were experiencing financial harm from compulsive spending and asked for help. Instead nothing was done, which allowed her to continue to spend and be trapped in the cycle of requesting account closure, but being unable to do this because of pending transactions. Revolut has explained that customers have access to an in-app gambling block, card payment freeze and online payment block. Any of these would have allowed Miss H to prevent further spending and I’m satisfied that this is something she intended to do. As such, I think Revolut has failed to provide a vulnerable customer with appropriate information about the tools available to them. The impact on Miss H Miss H has provided the statements for her main account and evidence from that bank confirming that they had applied a block which prevents any card payments or transfers to gambling merchants. These statements show no evidence of gambling between July 2025 and December 2025, but it does show she was taking out lending and some of it was sent to her Revolut account. Since the account with Revolut has closed, I can see that Miss H’s gambling activity has ceased and based on the evidence I currently have, there’s nothing to suggest that she’s set up an account elsewhere. So, I’m satisfied that once Miss H was aware of the gambling blocks available to her and was able to apply them to her account, she stopped spending in a harmful and compulsive way. So it seems likely to me that had she received the relevant information sooner, she wouldn’t have experienced the level of harm she did.

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I’ve also reviewed the transaction history of Miss H’s Revolut account and can see her payments went to UK-based sports betting companies – all of which can be controlled by the blocks offered by Revolut. Based on what I’ve seen, there’s no evidence on either account to suggest that she would have circumvented the blocks that could have been placed. And looking at the nature of the payments being made, I think it’s likely that they would have been prevented by any of the available blocks. On the balance of probabilities, I currently think it’s more likely than not that had Miss H been told about the gambling block, card freeze, or online payment block available to her, she would have enabled it. Which would have stopped the spending and allowed her to close the account if she felt the urge to gamble. Miss H has told our service that she took out lending to fund the gambling activity. After reviewing her statements, I can’t reasonably say that the lending was directly linked to the payments that left her Revolut account and I can only hold Revolut liable for their actions. But I can see that the continued gambling spending would have led to increased stress to Miss H trying to meet her repayments and obligations. Miss H was in touch with our service regularly while she was trying to close her account with Revolut and it’s clear that the responses she received and the continued compulsive spending was causing her significant distress over a long period of time. Redress Revolut were aware of Miss H’s circumstances in late July 2025, and they issued their response to her complaint on 5 August 2025. Revolut are expected to treat vulnerable consumers fairly and offer reasonable and tailored support under the principles set out by the FCA. In this case it appears that not only did Revolut fail to do this when Miss H notified them in July that she was spending in a harmful manner and needed help, but it repeatedly failed to offer any meaningful support or even acknowledge her request for help when she asked for her account to be closed multiple times after this date. This was despite the fact that it had tools available that she could have used. And when it finally did tell Miss H about the tools available, I’m satisfied she did avail of them and they were genuinely useful for her. Which means I’m also satisfied that if she’d found out about them sooner it would have had a meaningful impact and it would have prevented her experiencing the level of financial harm she did. Based on the information I currently have, I think that this would have prevented her attempts to gamble as the transactions would have been caught by the available blocks and she would have likely closed the account to prevent further temptation to spend. As such, I think Revolut should refund any gambling related payments from 5 August 2025 to the date the account closed after deducting any winnings that came into the account. I think this has led to a significant impact on Miss H between August and December 2025 and I think £500 compensation is a reasonable way to recognise this. My provisional decision My provisional decision is that I’m currently minded to uphold this complaint and direct Revolut Ltd to do the following; • Refund any gambling payments that left Miss H’s account from 5 August 2025

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onwards after deducting the winnings she received. I estimate this to be approximately £6,850. • Pay 8% simple interest from the date the transactions leave the account to the date that the settlement is paid to Miss H. • Pay £500 compensation. Responses I asked for both parties to let me have their responses by 27 February 2026. Miss H accepted my provisional decision, however Revolut disagreed with the outcome I had reached. They provided a detailed response, which I’ve summarised into key points below. • They accepted error for not providing information about the blocks sooner and they agreed with the £500 compensation to reflect this, but they didn’t think that they were the direct cause of Miss H’s losses. • They believe that the outcome sets a precedent that banks should be liable for refunding genuine voluntary payments made by customers. • Miss H raised a false fraud claim which compromises whether her testimony and reasons behind making the payments can be relied upon. • Miss H stopped gambling for three months before starting again in October 2025. This goes against the argument that she was locked in a cycle of spending, particularly as she could have closed the account during that three-month period. • Miss H told Revolut that closing the account wouldn’t be enough because she could open a new one and keep gambling, and they think Miss H would have circumvented the gambling controls even if they were placed on the account. 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. Setting a precedent At no stage have I stated that Revolut should change their procedures and processes. My decision is based on the unique circumstances of the individual complaint. We assess each case on its own merits. The decision to hold the bank liable for the losses isn’t an arbitrary one, but one based on the specific circumstances of the individual complaint. Miss H’s behaviour In the circumstances, I think it’s reasonable to question Miss H’s behaviour, but we must consider that the actions taken are those of a vulnerable individual suffering from an addiction. I agree that the fraud claim raised in May 2023 may not have been genuine, particularly as it was abandoned quickly when verification steps were requested. I think this shows that Miss H was attempting to recover her losses, however it doesn’t lead me to think that the same behaviour is happening now. Revolut are correct that Miss H’s gambling activity stopped for three months before starting again in October 2025 and the account could have been closed during that period. I can see a pattern on this account which shows long periods of inactivity followed by a spree of

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gambling activity with a high number of low value payments. Miss H has said that this pattern is usually linked to her mental health or difficult life events that she’s experiencing. I think it’s likely that the closure of the account was requested because she’d disclosed the challenges she was experiencing and when the spending started again in October 2025, she didn’t think there were any other options. I think it’s unlikely that Miss H would have felt it was necessary to close the account before October 2025 as she wasn’t experiencing a compulsion to spend at the time. The closure was requested to prevent further harm as she didn’t think there were any other options and it makes sense that this was requested while the harm was taking place. This behaviour supports the importance of spending tools for this customer. The spending control is a preventative measure and had Miss H been made aware of this at the right point, it would have likely been applied and in place to prevent the spree from taking place. Overall, I don’t think this behaviour compromises Miss H, instead it evidences why she would be so reliant on the tools available to her. Success of the spending controls I’d considered what Miss H had said during the chat with Revolut. It’s clear that she was concerned that simply closing the account may not be effective, instead she wanted a permanent block to be placed. Miss H has told our service without prompting that she’s provided her identity documents to another party to ensure that she’s unable to open another account or obtain any further credit, so she’s identified this risk and taken measures to prevent it. I had also considered whether it’s more likely than not that Miss H would have circumvented any blocks that have been placed. It’s important to note that Revolut have more blocks than the gambling block and as the account was solely used for gambling, I think she would have utilised card freezes and online payment blocks as well as the gambling block to prevent further spending. I’ve also reviewed the statements for her main account which shows no signs of gambling related payments since her Revolut account was closed, and I’ve received evidence of the blocks in place. This behaviour suggests that she wouldn’t have made payments that couldn’t have been prevented by the blocks and the layers of preventative measures put in place by Miss H would have likely stopped her from being able to use her main account for spending, and she wouldn’t have opened a new account elsewhere. Overall I can understand why Revolut have disagreed with my provisional decision as these are genuine payments. And I want to assure them that I’ve taken their comments on board and I’ve carefully considered the possibility that the blocks may not have prevented the spending. However, I must make an on balance finding, considering the specific circumstances of this complaint, on what I think was most likely to have happened had Revolut’s error not been made. And after taking these comments on board, it doesn’t persuade me to change my outcome. I’m still satisfied that Revolut failed to offer meaningful support to their customer after being notified that she was spending in a harmful way. And had they done this, it would have resulted in activation of the available spending controls which would have prevented a large amount of spending. As such, after taking everything on board, I haven’t been provided with anything that compels me to depart from my provisional decision, so I fully adopt this as part of my final decision.

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My final decision My final decision is that I uphold this complaint and direct Revolut Ltd to do the following; • Refund any gambling payments that left Miss H’s account from 5 August 2025 onwards after deducting the winnings she received. I estimate this to be approximately £6,850. • Pay 8% simple interest from the date the transactions left the account to the date that the settlement is paid to Miss H. • Pay Miss H £500 compensation. Under the rules of the Financial Ombudsman Service, I’m required to ask Miss H to accept or reject my decision before 2 April 2026. Chris Lowe Ombudsman

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