Account suddenly suspended without warning

Revolut unsuspended my account at 07:51 GMT this morning. I received multiple push notifications, including messages from Support and automated messages notifying me that my Apple Pay cards had been reactivated.

The explanation from Support was rather unsatisfactory. Because I understand this was Compliance, as opposed to normal Support with whom one can have fruitless discussions, I pushed for an explanation.

:r: Hello, my name is [redacted]. I would like to apologize for the long wait in the queue, this was caused by an unusual amount of requests at this time. I’ll look right into your query! Your account has been locked by our automatic security system, due to which we need to complete a due diligence check. Let’s see what we can do to unlock your account!

:r: I have unlocked your account and it is now fully operational. Have a nice day!

Me: Thank you. But what caused my account to be suspended without any warning?

:r: Sometimes accounts get flagged by our automatic security system, which causes them to be locked. This only happens to keep your money and your account details safe and sound. Even so, we’re going to do our best to get your account working again as quickly as possible. Unfortunately we can’t give away details about why some accounts get locked.

Me: Paragraph 24 of Revolut’s terms and conditions defines the scenarios where Revolut may suspend an account:

"We may close or suspend your account immediately, and end your access to our website, in exceptional circumstances. Exceptional circumstances include the following:

A if we have good reason to suspect that you are behaving fraudulently;

B if you haven’t given us (or someone acting on our behalf) any information we need, or we have good reason to believe that information you have provided is incorrect or not true;

C if you’ve broken these terms and conditions in a serious or persistent way and you haven’t put the matter right within a reasonable time of us asking you to;

D if we have good reason to believe that your use of the Revolut app is harmful to us or our software, systems or hardware;

E if we have good reason to believe that you continuing to use your account could damage our reputation or goodwill;

F if we have asked you to repay money you owe us and you have not done so within a reasonable period of time;

G if you’ve been declared bankrupt; or

H if we have to do so under any law, regulation, court order or ombudsman’s instructions.

We may also decide to close or suspend your account for other reasons. We would contact you through the Revolut app at least two months before we do this."

I added letters A to H for ease of reference. Which of these scenarios triggered my account to be suspended?

:r: I already informed you that we cannot disclose how our system works.

:r: And I will be not providing you with any further information as it might expose our system to the danger of compromisation of confidential procedures.

:r: Your account is unlocked and fully operational and I will gladly assist you with anything, other than releasing already explained confidential information.

Me: I’m not asking how your system works. I am alleging that Revolut breached paragraph 24. Which of these 8 reasons do you believe means that Revolut did not breach contract?

:r: We did not breach any contact of usage, we have followed ir and it states that we can limit your access at any time which happened as your account was locked by our system. However, I will repeat again, we cannot provide you with any information as to why the system locked your account or how the system works at all.

Me: Where did it say that you can limit access at any time?

:r: “We may close or suspend your account immediately, and end your access to our website, in exceptional circumstances” - which means the system can limit your account at any time and if that happens we will gladly help you unlock the account, which I did the very second I got assigned to your case.

Me: None of these “exceptional circumstances”, to which I have added letters A to H, occurred. Therefore Revolut is in breach of contract for which I expect to be compensated by £150.

Me: Which of the “exceptional circumstances” are you relying on in order to defend my allegation of a breach of contract?

:r: Sometimes accounts get flagged by our automatic security system, which causes them to be locked. This only happens to keep your money and your account details safe and sound. Even so, we’re going to do our best to get your account working again as quickly as possible. Unfortunately we can’t give away details about why some accounts get locked.

Me: You have not defended or challenged my allegation that you breached contract. If you cannot cite which of the “exceptional circumstances” you are relying on, then my allegation is undefended.

:r: I have already said couple of times, we will not be providing you with any further information in relation to this topic. And sadly, but that will not change no matter what you say. We have no obligation, not even are allowed to inform you with how our system work or why your account was locked by our system.

Me: For the record, my allegation is unchallenged and undefended.

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Well, they don’t say that the list is conclusive… but I guess it is difficult to argue that a false positive by some sloppy algorithm with a bit of machine learning thrown at your data is “exceptional circumstances”. Also, a flag raised by some piece of code, the reason of which they probably don’t understand themselves (such is the nature of ML), is hardly “good reason”.

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Welcome back. :sweat_smile:

Well those generic answers where expected. What will you do now? Did you had to provide and upload any documents at all now?

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I will make a formal complaint to Revolut, requesting at least £150 in compensation. If they fail to comply, then I will complain to the Financial Ombudsman Service, which will take months for a response.

Compliance did not ask for any documents at all, which further proves that the automated process created a false positive. Don’t forget that automated processes are created by humans, so it is nevertheless human error by Revolut.

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Maybe the usage of credit cards to add money is more risky than using a debit card. Credit cards can be found lying on the street (exaggerating there) while debit cards are usually tied to a full bank account.

I also found this:

We advise using your own card to add money to your balance. If someone else would like to add money to your Revolut account, they can send money to your account instantly via their Revolut app.

This is exactly what I do for my girlfriend. I top up my Revolut account with my credit card to earn points, send it to her via Revolut, and she pays me from her traditional bank account to my traditional bank account. I’m glad to read that this is an approved procedure.

Ok, I can see why it may looked suspicious - you forwarded amount X from your credit card to another account.

I have done this many times without any issues. And your quote above proves that Revolut approves of it, so it’s unlikely to be the cause.

Before submitting a formal complaint to Revolut, followed if necessary by a complaint to the Financial Ombudsman Service, I am sending a GDPR request to Revolut in an attempt to ascertain the reasons for the suspension of my account. Revolut has a legal obligation to supply the data, even if it doesn’t want to. For the benefit of others whose accounts have been similarly suspended, you can send the following text to dpo@revolut.com:

Pursuant to Article 15 of Regulation (EU) 2016/679 (General Data Protection Regulation), I would be grateful if you could send an electronic copy (or a secure download link) of all data that Revolut holds about me to the e-mail address that you have on file for me, [E-MAIL ADDRESS]. Please ensure that the data includes in particular:

  • All internal correspondence concerning the suspension of my account between [DATE] and [DATE]
  • All external correspondence concerning the suspension of my account between [DATE] and [DATE], including data received from third parties
  • All documented reasons for the suspension of my account between [DATE] and [DATE]

I refer you to https://ico.org.uk/for-organisations/guide-to-data-protection/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/right-of-access/#10 which states “If you have doubts about the identity of the person making the request you can ask for more information. However, it is important that you only request information that is necessary to confirm who they are. The key to this is proportionality”. As I am sending this request from, and asking for the data to be sent to, the e-mail address that you hold on file for me, and I have already supplied Revolut with my proof of identity, there is no doubt about my identity. Therefore I am not attaching proof of identity.

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Thanks, NFH, for educating the ordinary people like myself. That’s some really useful info, and the thread as a whole is really helpful! Cheers!

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Do these Regulations also apply to users from the UK or also the ones that live outside of the UK?

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That is a very helpful question, and something that I was considering pointing out.

Article 3(1) of the GDPR states that “This Regulation applies to the processing of personal data in the context of the activities of an establishment of a controller or a processor in the Union, regardless of whether the processing takes place in the Union or not”. In order words, the GDPR applies to Revolut as a company based in the EU, and there is no dependency on where the data subject is located.

Anyone can complain to the Financial Ombudsman Service in the United Kingdom, irrespective of the country they live in, about a financial business operating in the United Kingdom. Therefore all customers of Revolut can use the Financial Ombudsman Service. The cost is always zero to the consumer/complainant, but the financial business has to pay a case fee of £550, irrespective of the outcome (i.e. even if the FOS finds in the financial business’s favour).

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From private messages I’ve received, I know that some of you would like a complaint template. I am waiting for Revolut to respond to my GDPR request before submitting my own complaint, so that my complaint is based on all the facts. I suggest that others affected do likewise. Once I submit my own complaint, I will post a complaint template here.

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Thank you so much for your really valuable input, @NFH. Revolut users should be aware of their rights and options to fight these random decisions.

Frankly, I am still quite passionate about Revolut, in my current situation it is by far the best available banking product and I am practically using it as my primary account. However, the fear of random account suspension is definitely a thing in my case.
It’s absolutely outrageous how suspensions are being handled right now. Revolut doesn’t seem to care about the possible implications of account suspension, even for 24 hours. If it happens to collide with any of my Revolut-linked SEPA direct debits, then it’ll put me in some seemingly endless state of limbo with countless late fees, service suspensions and love letters from various companies.
I asked Revolut support multiple times about verifying my account. I have all documents ready and I want my account to be verified in order to avoid all of this crap, but apparently it’s impossible. Instead I have to hope for the best and pray that it won’t happen at an inconvenient time…

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True. Imagine a scenario where car or house insurance premiums are taken by monthly SEPA direct debit, and then your car is stolen or your house suffers structural damage. Your insurer could refuse to pay a claim because Revolut rejected the direct debit for the monthly premium. Then who is liable? Revolut? It could be a massive consequential loss claim suffered by Revolut as a result of a badly-implemented procedure.

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The compliance team waiting times seems to be the heart of the problem.

Automatic suspension would be perfectly reasonable if a human reviewed it within a few hours, even if only to triage the cases.

I should imagine this is also a stumbling block to Revolut operating with a full-fat banking licence…

No, automatic suspension is never reasonable for any length of time. Any decision to suspend an account should be taken only by a human. Even a few hours can significantly disrupt the customer’s life, particularly if they are stranded abroad. When TSB in the UK locked thousands of customers out of their accounts in error for a few hours, it paid hundreds of pounds in compensation to each customer who complained. It is a very serious matter.

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I suppose it depends on the circumstances.

For example, I recently opened a Lloyd’s account for the incentive. I put 1.5k in and immediately took it out to avoid the account fee. My account was suspended until I called the displayed number and answered their questions.

Obviously, the suspension was automatic, but it was promptly reviewed by a human.

It seems to me that the problem with Revolut is operational. The principle of automatic suspension to avoid loss is OK in itself.

Yes, automatically suspending compromised payment cards to avoid loss is common practice by many card issuers. But automatically suspending the whole account when there is no indication of fraud or crime against the bank or the account holder is not acceptable.

If automatic systems think the whole account has been compromised, it still falls into the same situation as I described above. Revolut just fails to deal with automatic suspension in a timely manner - that’s the issue for me