Not upheld: Cifas marker registration for misuse of facility / suspected financial crime complaint against Revolut Ltd

Decision detail

Summary

Mr K complained that Revolut unfairly recorded a Cifas marker against him for receiving a £2,000 payment he claimed was for immigration services. Mr K stated he acted only as a middleman, receiving funds from friend 'A' to pass to 'N', whom he believed to be a solicitor. The ombudsman upheld Revolut's decision, finding that the combination of circumstances—including Mr K's failure to verify N's credentials, suspicious meeting arrangements in a Lidl car park, instructions to pay N's wife, and rapid transfer of funds via Remitly to an international recipient—demonstrated Mr K was complicit in receiving fraudulent funds and knew or ought to have known the payment was illegitimate.

The Ombudsman's reasoning

The ombudsman applied the Cifas standard requiring reasonable grounds to believe financial crime occurred, not proof beyond reasonable doubt. The ombudsman also required strong evidence of complicity, meaning Mr K knew or ought to have known the payment was illegitimate. The combination of factors—receiving funds on behalf of an unverified individual, arranging meetings in a car park, instructions to pay N's wife, and rapid transfer via Remitly to an international recipient—constituted highly unusual and suspicious conduct. A reasonable person would have conducted basic due diligence on N before facilitating payments. The rapid transfer to Remitly is behaviour commonly associated with moving fraudulent funds.

How this compares

Source

Read the original decision on the Financial Ombudsman Service website