Lloyds Young Person Social Media CIFAS Marker Removal

Our client was 14 years old when somebody on social media offered what were described as quick ways to make money. Wanting to earn something and lacking the experience to recognise the risk, the child handed over card details and became entangled in suspicious payment activity.

Lloyds detected the pattern and filed a Misuse of Facility marker. That meant a serious fraud label was placed against somebody who was still a child at the time of the conduct. The complaint therefore had to do more than challenge the payment pattern. It had to force attention onto age, exploitation and proportionality.

The report confirmed a Misuse of Facility marker, regular payment fraud, filed by Lloyds Bank PLC. Our analysis immediately identified the age factor, the client was a minor at the time of the alleged conduct.

That should have mattered much more than the file suggested it did. CIFAS filing standards and FCA vulnerability guidance both require serious attention to age and vulnerability. A marker against a child cannot simply be treated as if the bank were dealing with a fully informed adult making a deliberate fraud decision.

The complaint focused on minority, exploitation and proportionality. We set out that the client was a child, had been recruited by an older person through social media and could not realistically be assessed by the same standard as an adult knowingly facilitating fraud.

We also pressed Lloyds on the consequences of the filing. A six-year fraud marker against a child is not a neutral administrative step. It carries adult consequences for education, banking and future credit access. Once that proportionality point was brought together with the vulnerability evidence, the original filing became much harder to defend.

Lloyds reviewed the complaint and acknowledged the vulnerability factors.

The marker was removed within three weeks. Cases involving young people are often among the strongest for removal because the proportionality argument is so powerful. Where the bank has not properly confronted the customer's age and exploitation, the file can be much weaker than the marker suggests.