Revolut CIFAS Marker — Marker removed
The situation
D's Revolut account received a series of payments from contacts that Revolut flagged as suspicious. The account was frozen and closed, and a CIFAS Misuse of Facility marker was placed on D's record without prior notification. D discovered the marker when trying to open a bank account elsewhere and was declined.
Our approach
Our system identified this as a classic Misuse of Facility case where the key question was whether D had acted dishonestly. The complaint challenged Revolut on three grounds: (1) the standard of proof — Revolut had not demonstrated D knew the payments were suspicious, (2) data accuracy under UK GDPR Article 5(1)(d) — the marker implied dishonesty where none existed, and (3) proportionality — a fraud marker was disproportionate to the circumstances.
Issuer response
Revolut reviewed the complaint and confirmed the marker had been removed within 3 days. They acknowledged that the evidence did not meet the CIFAS filing standard for demonstrating dishonesty.
Result
Marker removed within 3 days of sending the complaint. D was able to open bank accounts normally again within a week.
Key takeaway
Many Misuse of Facility markers are placed reactively when suspicious transactions are detected, without proper investigation into whether the account holder acted dishonestly. A structured complaint that challenges the standard of proof can resolve these quickly.
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