Bank of Scotland Plc trading as Halifax · DRN-6178274

The complaint Mr S complains that Bank of Scotland Plc trading as Halifax acted unreasonably when blocking his debit card whilst he was abroad. What happened Mr S has a Halifax account. On 5 September 2025 whilst on holiday abroad, Halifax blocked a transaction even though Mr S entered a verification code (it seems this happened twice). Mr S then found out that Halifax had blocked his debit card. He says it did that without adequate warning or effective support, which left him in a vulnerable position and without access to essential funds. Further, he says he had to go through repeated and lengthy verification processes before the issue was resolved. He complained to Halifax. Halifax looked into the complaint and although it paid £30 as a goodwill gesture, it didn’t think it had done anything wrong. It explained that the card was blocked because it believed Mr S’ details may have been compromised. It said its fraud team may not always contact the customer for security reasons and may only disclose further information once the customer gets in touch. It added that if it can’t explain its suspicions in advance, it will discuss them during the subsequent contact with the account holder. Whilst it recognised Mr S’ frustration, it said one of its main responsibilities is to safeguard his account from fraud. Mr S continued to raise concerns with Halifax. It assured him that all relevant procedures and security protocols had been correctly followed. Mr S brought his complaint to the Financial Ombudsman Service. One of our Investigators looked into the complaint. But he decided that Halifax had acted reasonably in blocking the card in an effort to safeguard Mr S’ account. He also didn’t think the block was in place for an excessive amount of time, particularly given that Halifax needed to confirm additional security details with Mr S. The Investigator was also satisfied, based on the evidence he’d seen, that Mr S had access to funds for essential items during the time his card was blocked. He didn’t think Halifax needed to do anything else. Mr S didn’t agree and provided a number of comments in response. In particular, he said the Investigator’s opinion didn’t reflect the foreseeable consequences of Halifax’s actions. He also highlighted what he believed to be Halifax’s inconsistency in the way it applied its anti- fraud policies given that it approved a credit card payment on the same day without any anti- fraud checks being needed. In Mr S’ opinion, this demonstrated that the block on his debit card was unnecessary and unfairly disruptive. As no agreement could be reached, the matter has been passed to me to decide. 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.

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Although I’ve considered everything Mr S has said, in keeping with our Service’s approach to resolving complaints with minimum formality, I’m not intending to address each and every point made. Instead, I’ll comment on those that I believe go to the heart of Mr S’ complaint. Mr S says he’s not suggesting Halifax doesn’t have the right to block transactions where suspicious activity is detected. However, he’s made it perfectly clear that he doesn’t think it acted reasonably, or proportionately, in his particular situation especially as he was abroad when his card was blocked. I have no doubt that Mr S was frustrated and inconvenienced by his card being blocked, especially as he was abroad when it happened. However, as I’ll outline, I’ve seen nothing that persuades me Mr S’ frustration and inconvenience was caused by Halifax acting unfairly or unreasonably. I don’t agree that the fact Mr S was able to make a payment on the same day using his credit card means Halifax acted in a disproportionate way when blocking his debit card. There can be many reasons why fraud detection systems identify potentially suspicious activity. So, the fact that a payment to a different payee using a different card was allowed, doesn’t demonstrate that Halifax did something wrong in connection with the payment that was attempted using the debit card. Mr S says that Halifax could have foreseen the impact the block would have on him. Again, I can see why being abroad potentially made things more difficult for Mr S. But Halifax is still expected to react when it identifies a potential risk. That may mean it’s required to take immediate steps to protect an account from harm. Mr S’ account terms say [in relation to stopping a payment] “we’ll tell you before we do this and why, unless a legal or security reason means we can’t. In that case, we’ll tell you as soon as possible afterwards”. Here, it seems that, for security reasons, Halifax wasn’t able to tell Mr S before the payment was stopped, or about the card block. But when he contacted Halifax, it told him it had blocked his card because it had concerns about whether certain payments were genuine (including the one that Mr S was aware hadn’t been authorised). I’m satisfied Halifax explains in the account terms that it won’t always be possible to say anything upfront about a payment/s being stopped. And I understand that, in certain circumstances, the fraud team won’t routinely call a customer but will instead expect them to get in touch to discuss the matter. Again, whilst this was clearly a frustrating situation for Mr S, I can’t see that Halifax acted outside of the agreed terms and conditions here. Mr S has concerns with the verification process itself – for instance he says there were long delays between interactions. I accept that Mr S was likely comfortable with the payment he was trying to make and may have thought this was a simple matter to resolve. However, it’s not for me to tell Halifax what its fraud checks should consist of. So, I can’t fairly say that it ought to have deemed the early verification from Mr S as sufficient. Clearly, Halifax was concerned enough that it felt it necessary to block Mr S’ card and ask him to provide further verification/information. Again, whilst Mr S may have felt certain steps were unnecessary, that doesn’t persuade me Halifax did something wrong. I can also appreciate that time was of the essence for Mr S given that he’d indicated he needed to withdraw funds at a local post office before it closed. However, Halifax still needed to take reasonable steps to satisfy itself that everything was in order. That was particularly important here, as I can see that Mr S initially indicated he didn’t recognise some of the transactions that Halifax had flagged (although he later confirmed he’d made them). I’ve reviewed the interaction between Mr S and Halifax. I can see it took about 3.5 hours overall between Mr S first contacting Halifax (which appeared to happen fairly soon after he first encountered problems) and it releasing the block. Given the security checks Halifax needed to perform and the information it needed Mr S to provide, I don’t find that amount of time excessive. And apart from a period of about 45 minutes at the beginning before Mr S

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was connected to an adviser, I haven’t identified any particularly long delays between interactions after that. And certainly none lasting 45-60 minutes as Mr S has suggested. I can see that for the most part (apart from maybe one instance where there seems to be a gap of about 20 minutes before Halifax sent a link to allow Mr S to upload information) Halifax responded within less than 10 minutes and often within only a few minutes. Overall therefore, I think Halifax responded in a reasonable way. It’s evident Mr S was frustrated by some of Halifax’s questions. That’s evidenced by him saying things such as “how many more steps”; “you’re blocking my card on a ridiculous amount”. Again, it’s for Halifax to determine what steps it needs to take when a potential risk is identified. And whilst it’s expected to approach things in a reasonable and proportionate way, there’s also an expectation that the customer will comply with any reasonable requests for information. Notwithstanding Mr S’ obvious frustration, I’m satisfied it was reasonable for Halifax to take him through the relevant process. And I imagine it was probably fairly limited in what it could say until it had looked into things further. Also, as the interaction happened via the chat function rather than Mr S calling in, I think that naturally meant things took a little longer. But even allowing for that, as I’ve already said, I’m not persuaded the overall timescale was excessive. Mr S says that the £30 goodwill gesture Halifax paid doesn’t recognise a complete loss of funds, nor the time lost due to repeated blocks and verification procedures. He also doesn’t think it’s a fair payment compared with £100 that his partner apparently received. I make my decisions on the basis of what I consider to be fair and reasonable in the particular circumstances of the case. I’m considering Mr S’ complaint here, so it wouldn’t be appropriate to comment on the compensation his partner received. And if I were to direct Halifax to do anything more or to pay a greater sum in compensation to Mr S, I’d need to be satisfied, overall, that it had done something wrong or had otherwise treated him unfairly. Based on the factors I’ve already set out, I’m not persuaded that’s the case. I don’t wish to downplay the obvious impact that these events had on Mr S. And I can understand his added frustration that by the time Halifax’s checks were completed, the local post office had closed for the day. So, Mr S says he still had no practical access to his funds even once the block was lifted. But I don’t think that’s something Halifax can fairly be held responsible for. And whilst I accept that Mr S might have been reluctant to access his funds by other, more expensive means (such as through a cash machine) once the block was lifted, I’m satisfied that was Mr S’ choice rather than him being prevented from doing so. Further, it seems likely, based on other points he made, that Mr S had access to a credit card for essential items during and after the period the block was in place. In the particular circumstances described here, I don’t think Halifax did anything wrong or treated Mr S unfairly. So, I’m not intending to direct it to take any further action. My final decision I don’t uphold this complaint. Under the rules of the Financial Ombudsman Service, I’m required to ask Mr S to accept or reject my decision before 15 April 2026. Amanda Scott Ombudsman

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