Barclays Bank UK PLC · DRN-6236068

The complaint Ms R complains Barclays Bank UK PLC (“Barclays”) hasn’t refunded funds she lost as the result of a scam. What happened Both parties are familiar with the circumstances of the complaint, so I’ll only summarise the key details here. Between 2 and 24 September 2025, Ms R made several payments totalling approximately £65,000 towards what she thought was a legitimate investment opportunity. She moved funds from her Barclays account to an account she held with an electronic money provider I’ll call ‘W’, before moving them on again to a money transfer service in USD. Ms R said the funds appeared in her account on the scammer’s trading platform where they were lost to the scam. Ms R realised she had been scammed after speaking with her daughter and contacted Barclays, but it didn’t refund her. Unhappy with Barclays’ response, Ms R raised the matter with the Financial Ombudsman Service. One of our Investigators looked into the complaint and didn’t uphold it. They thought Barclays should have intervened further but that it wouldn’t have made a difference even if it had, due to the coaching Ms R was receiving from the scammer. Ms R has also raised a complaint against W which I will address separately. As an agreement could not be reached, the complaint has been passed to me for a final decision. 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. I’m sorry that Ms R has been the victim of a scam. I realise she’s lost a significant sum of money at an already difficult time, and I don’t underestimate the impact this has had on her. And so, I’d like to reassure her that I’ve read and considered everything she’s said in support of her complaint. This includes the vulnerabilities that Ms R disclosed to us, due to their sensitive nature I won’t detail them here. However, I’ll focus my comments on what I think is relevant. If I don’t mention any specific point, it’s not because I’ve failed to take it on board and think about it, but because I don’t think I need to comment on it to reach what I think is a fair and reasonable outcome. I know this will come as a disappointment to Ms R but having done so, I won’t be upholding her complaint for broadly the same reasons as our Investigator. I’ll explain why. In broad terms, the starting position at law is that banks and other payment service providers are expected to process payments and withdrawals that a customer authorises it to make, in accordance with the Payment Services Regulations and the terms and conditions of the customer’s account.

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Ms R authorised the payments in question here and knew funds would be leaving her account – so even though she was tricked into doing so and didn’t intend for her money to end up in the hands of a scammer, she is presumed liable in the first instance. But as a matter of good industry practice, Barclays should also have taken proactive steps to identify and help prevent transactions – particularly unusual or uncharacteristic transactions – that could involve fraud or be the result of a scam. However, there is a balance to be struck: as while banks should be alert to fraud and scams to act in their customers’ best interests, they can’t reasonably be involved in every transaction. I’ve also thought about the Contingent Reimbursement Model which Barclays is a voluntary signatory of and the Authorised Push Payment reimbursement rules. Neither cover payments made to an account in a customer’s name, and so aren’t relevant here. I’ve thought about whether Barclays acted fairly and reasonably in its dealings with Ms R when she made the payments, or whether it should have done more than it did. Ms R made numerous payments from Barclays to W. I’m satisfied that some of the payments ought to have concerned Barclays that Ms R was at risk of financial harm from fraud such that it should have intervened prior to processing the payments. And while it could be argued that Barclays ought to have intervened on more occasions, I’m not persuaded that any further intervention from Barclays would have uncovered the scam or prevented Ms R’s loss. I’ll explain why. I should explain that for me to find it fair and reasonable that Barclays should refund Ms R requires more than a finding that it ought to have intervened further than it did. I would need to find not only that Barclays failed to proportionately intervene where it ought reasonably to have done so – but crucially I’d need to find that but for this failure the subsequent loss would’ve been avoided. That latter element concerns causation. A proportionate intervention will not always result in the prevention of a payment. And if I find it more likely than not that such a proportionate intervention by Barclays wouldn’t have revealed the payments were part of a fraud or scam, then I couldn’t fairly hold Barclays liable for not having prevented them from being made. Barclays spoke with Ms R by phone prior to processing a £5,000 payment on 9 September 2025. I’ve listened to the call and Ms R wasn’t forthcoming with Barclays. Barclays started the call by saying it was important for Ms R to tell it if anyone had told her what to say or lie to the bank as it could be a scam, Ms R confirmed she understood. In summary when asked the reason for the payment Ms R said Barclays wasn’t great for savings so she’d decided to open an account with W and move her funds. She also said W was better for international transfers and she would be using it for travelling. Barclays asked if she’d opened the account with W herself, to which she said yes. It also asked if she’d been asked to download remote access software, been pressured to make the payment and if there was third-party involvement of any kind. Ms R answered no to all these questions which we know wasn’t accurate. At no point during the call did Ms R say she would be investing her funds and given the destination of the payments it isn’t something Barclays would have known unless she had told it. This meant Ms R didn’t receive investment scam warnings. A bank’s intervention relies on a customer being accurate and when that doesn’t happen, as is the case here, it can impact the actions a bank takes. On 8 September 2025, the day before the above intervention, Ms R made three separate £5,000 payments to her account with W, and I think Barclays ought to have intervened on the third payment made that day. However, due to the proximity of that payment and the

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payment Barclays did intervene on I’m not persuaded that an intervention a day earlier would have made a difference. Ms R acknowledges by the point of Barclays intervention on 9 September 2025, she was already heavily under the scammer’s spell, and so I’m satisfied this would also apply on the payment had Barclays intervened a day earlier. I therefore think she would more likely than not have behaved in a similar way and not been forthcoming with Barclays and I’m not satisfied the scam would have been uncovered. Other interventions I’ve also considered information we’ve been provided from Ms R’s loan provider, when she took a loan to fund the scam. The loan provider spoke with Ms R by phone as part of the application process. I’ve listened to the call Ms R had with the loan provider and when asked what the purpose of the loan was Ms R said it was for home improvements and was able to answer the provider’s further questions regarding the planned works such that it was satisfied and approved the loan. She was specifically asked if she was borrowing for investment purposes and confirmed she wasn’t. Ms R said the scammer told her exactly what to say to get the loan approved, which she did. Ms R’s testimony is clear, she told us the scammer gave her direct coaching on a daily basis, and she said she operated under remote access manipulation, with the use of remote access software. She also said that her and the scammer rehearsed what she should say in any intervention calls from her bank, so it’s clear she was being heavily coached. So, although, I do think Barclays should have intervened on the later higher value payments, due to the heavy coaching and guidance Ms R was receiving, I’m not persuaded this would have made a difference in uncovering the scam or preventing her loss. It therefore wouldn’t be fair or reasonable to hold Barclays liable for her losses. I’ve also considered if Barclays could reasonably have helped recover Ms R’s funds, when the scam was reported. However, given Ms R moved the funds to her account with W and quickly moved them on again, I don’t think there was any reasonable prospect of Barclays being able to recover her losses. I’m sorry to disappoint Ms R further, but I’ve thought carefully about everything that has happened, and with all the circumstances of this complaint in mind I don’t think Barclays needs to refund Ms R’s money or pay any compensation. I realise this means Ms R is out of pocket and I’m really sorry she’s lost this money. However, for the reasons I’ve explained, I don’t think I can fairly or reasonably uphold this complaint. My final decision My final decision is that I do not uphold this complaint against Barclays Bank UK PLC. Under the rules of the Financial Ombudsman Service, I’m required to ask Ms R to accept or reject my decision before 28 April 2026. Charlotte Mulvihill Ombudsman

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