Santander UK Plc · DRN-6254929

The complaint Mr A complains Santander UK Plc (“Santander”) blocked and closed his account, and in doing so failed to treat him fairly given he was abroad and unable to communicate with its request for information. Mr A is also unhappy about the poor customer service he received and for receiving erroneous letters from Santander about his account being joint – and in one instance, being addressed to a limited company he had nothing to do with. Mr A says Santander’s actions have caused him substantive distress, inconvenience and financial loss including flight costs to come to the UK. Mr A adds that he has missed payments which may have affected his credit file and he had insurance policies lapse. What happened The details of this complaint are well known by both parties, so I won’t repeat them again here in detail. Instead, I’ll focus on setting out some of the key facts and on giving my reasons for my decision. In June 2025, Santander sent Mr A an email requesting he contact it. Santander needed information about Mr A’s account activity to fulfil its regulatory obligations. Mr A says the email could not be responded to. Subsequently, Mr A says he tried calling Santander but because of where he was working overseas, his phone provider wouldn’t allow him to make long calls due to the cost given he was on hold for long periods. As Mr A didn’t provide Santander with the information it needed, his account was restricted in July 2025 and later closed. Mr A then travelled to the UK in September 2025. Mr A says he did this solely to resolve the issue with Santander. Unhappy, Mr A complained. Santander didn’t uphold Mr A’s complaint about the account being restricted and closed. Santander said it needed information from Mr A to fulfil its Know-Your-Customer (KYC) requirements, and despite making attempts to contact Mr A, he failed to contact it. So, Santander blocked his account. In a separate response, Santander offered Mr A £50 compensation for poor customer service as its agent failed to find a code for Mr A whilst on the phone. Also, in another separate response, Santander apologised to Mr A for the lack of information it gave him about the blocks on his account. It appears that Santander also offered Mr A £100 compensation for its poor service, which he refused. Mr A referred his complaint to this service. I’d like to assure Mr A that I have reviewed all of his submissions, even if I don’t summarise them in detail here. He should note that I will not be considering his point about a payment of £900 he says he didn’t make but debited his account. That’s because that complaint point doesn’t appear to have been made to Santander and it is a separate event to what I am considering here. One of our Investigator looked into Mr A’s complaint. In summary, their key findings were: • Santander had no way of knowing Mr A was abroad at the time it was asking for

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information to complete its KYC review. Santander was acting reasonably by relying on the contact details Mr A had provided • When Mr A provided the required information in late September 2025, Santander were happy to lift the restrictions, but Mr A chose to close the account • The £100 compensation Santander has offered Mr A is reasonable in the circumstances of the complaint. But as Santander had sent multiple warnings and a closure notice of two months’ to Mr A, it should not be held liable for any travel costs or other consequences Mr A didn’t agree with what our Investigator said and sent in more detailed arguments. He also sent a chat message log when he first discovered Santander needed information from him. As there was no agreement, this complaint was passed to me to decide. I then sent both parties my provisional decision in which I said I was planning on part upholding this complaint. For ease of reference, here is what I said: Provisional decision “I’ve considered all the available evidence and arguments to decide what’s fair and reasonable in the circumstances of this complaint. Having done so, I am planning on upholding this complaint in part. I’ll explain why. Banks in the UK, like Santander, are strictly regulated and must take certain actions in order to meet their legal and regulatory obligations. They are also required to carry out ongoing monitoring of an existing business relationship. That sometimes means banks need to restrict, or in some cases go as far as closing, customers’ accounts. To that end banks have rules they must follow to identify its customers, for establishing the purpose and intended nature of the business relationship, and origin of funds. This applies to both new and existing relationships. This is generally referred to as its customer due diligence rules – or also as KYC. Mr A feels Santander didn’t have basis to have carried out the KYC checks. But from the information I’ve been provided, I’m satisfied that this was done to fulfil Santander’s regulatory obligations. So, in theory, as Santander didn’t get the information it required from Mr A, it had basis to restrict and ultimately close Mr A’s account. But in requesting and gathering this information, I would expect Santander to act both reasonably and fairly and take into account a customers’ situation and any vulnerabilities they had. Mr A has sent me the text chat he had with Santander and as early as July 2025 I can see he explained he could not speak to Santander whilst abroad due to the excessive waiting time he was encountering and the call costs associated with this. Mr A’s escalating frustration and distress is clear to see from these notes as the issue went into August and September 2025. What’s more important is that Mr A made it very clear he needed Santander to either call him or offer another mode of communication in which he could find out what information was needed and then provide it. Mr A also offered to set up a POA (power of attorney) for his son to act on his behalf. Mr A was also clear that he was away in a third-world country for work and he could not easily travel back without losing income and paying substantive air fares. Having given this careful consideration, I’m satisfied that had Santander acted appropriately on this information provided to it by Mr A as early as July 2024, Mr A would most likely have

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complied with the information request, and his account would not have been restricted. I’m also satisfied that Mr A travelled back to the UK solely to resolve this matter given his attempts to resolve it in other ways was not being effectively dealt with. So, in conclusion, I find that Santander failed to act reasonably and as it ought to have when Mr A explained his predicament to it in July 2025 and onwards. That means Santander needs to put Mr A back into the position but not for what it did wrong. Mr A should note, that in mitigation, I have considered that he failed to meet the terms and conditions of his account by not updating Santander with correct contact details given he was abroad for a substantive period. What is clear is that Mr A suffered severe distress and inconvenience. This is borne out in the messages I have seen, and I think his reaction was reasonable given his Santander account was his main account from which he paid a multitude of regular payments including his mobile phone. Santander may argue it wasn’t able to help Mr A on its online chat but it had a duty of care to use that information appropriately. And given the vulnerable circumstance Mr A found himself in, Santander should have worked outside its normal processes here. To put things right, I am intending on directing Santander to: • Pay Mr A £750 for the considerable distress and inconvenience it has caused him • Pay him £901.30 for the cost of his flights back to the UK and then returning to work overseas in October 2025 • Provide Mr A with a letter explaining that any adverse credit or loss of benefits he incurred during the period his account was closed was because of its error and this should be rectified by his third-party creditor and/or insurance company As Mr A chose not to bank with Santander anymore following his return to the UK in September 2025, I make no direction for the account to be reopened” The deadline for further arguments and evidence to be presented has now passed. Both parties have responded. In summary, the key points they made and my responses are: Mr A’s response • Santander had an alternative international contact number for Mr A which it refused to call • Santander knew Mr A worked for extensive periods abroad as he spent over two weeks in the previous year attempting to complete a payment transfer for a house rental that Santander blocked • Santander should not have sent Mr A letters for information it already knew and had gathered from him • Compensation of £750 is far too low for the distress and inconvenience Santander caused Mr A to suffer. Mr A’s life savings had been compromised, and he had been made to feel like a criminal. Santander caused Mr A heightened anxiety and loss of sleep Santander’s response

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• Mr A says his phone provider would not allow him to make long calls. Is this something Mr A set up in relation to charges incurred? Santander also asked who Mr A’s phone provider was • Santander wanted to know where Mr A was when his account was blocked and what evidence Mr A has provided to show his sole purpose when returning to the UK was to resolve this issue • Santander also said Mr A contacted it via the chat service in July, but it appears Mr A then terminated the chat without reply. Mr A then contact again in August and is provided with an international number to call for the KYC team but advises he cannot make calls. Mr A provides an international number for Santander to call him on. Santander then tried to call Mr A’s number on 14 July 2025 and 23 July 2025 but there was no dial tone • Santander questioned why Mr A didn’t update it about not residing in the UK for a prolonged period • It appears Mr A received his regular monthly credit from his employer. So does Mr A have any evidence his trip back to the UK caused him a loss of earnings I then responded to Santander with the following points: • Santander will note that Mr A told Santander as early as July 2025 that he was having substantive problems calling Santander due to where he was working and the cost of calls which were being eaten up on a pre-paid basis by the wait times. I attached the chatbot messages Mr A had provided to show this • Santander will also note from the Alerts spreadsheet it had provided that it was only until late September 2025 that Santander attempted to call Mr A on the international number he had been providing to Santander since early July 2025. So, Santander were on notice about Mr A's acute communication needs which included his issues with emails and trying to call Santander • It doesn't matter which communication channel Mr A told Santander about these issues on, Santander had a duty to act on this information and to make reasonable adjustments. Santander failed to do this • I think it's a reasonable position for someone who is working in a destination like where Mr A was (Santander are aware of the location) to use a local prepaid phone to make international calls and for Mr A’s UK numbers - landline and mobile - to have been redundant • Mr A was abroad when the account was blocked • In relation to what evidence Mr A has provided to show he made the trip exclusively to the UK to resolve this matter; I said I was happy to make this finding based on what has gone on before - that is Mr A attempted to get Santander to contact him by a channel he could communicate on. And his attempts to establish his son as a POA where not accommodated. Mr A had also provided evidence in the form of an airfare receipt. Had Santander acted as it ought to have, Mr A would not have had to rush to the UK to prevent his account being closed, withdraw his funds and set up another suitable UK bank account

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• The evidence I’ve been provided with by Santander, and which I attached, did not show Santander attempted to call Mr A on his prescribed international telephone number. But those previous attempts, as shown by this technical evidence, were to Mr A’s UK numbers. I asked Santander to clearly show me that it had called this number abroad • I thought Santander’s comments about loss of income were immaterial as I was not planning to award any such losses in my provisional decision. And that I had already commented on Mr A failing to properly update Santander with his internal contact details from the offset in my provisional decision Santander responded that it had tried to contact Mr A has part of its KYC outreach. And it had attempted to call Mr A on the telephone number he provided on 14 and 23 July 2025 but there was no dial tone. 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. For the reasons in my provisional decision, and in responses sent to Santander – as above – I have decided to uphold this complaint in part. I will now address the key points both Mr A and Santander have made after my provisional decision. I note Mr A says Santander didn’t need to carry out the KYC exercise because it ought to have known, and had the details, it needed from him. But as I’ve said Santander has important regulatory and legal obligation to meet. And based on the information Santander has given me, I’m satisfied it’s KYC review was in line with those obligations. Mr A feels that £750 is not sufficient compensation for the distress and inconvenience he has suffered. But he hasn’t submitted any compelling evidence, other than the arguments I have already considered, to show why it should be higher. So, I’m satisfied £750 in compensation enough. Santander say it did attempt to call Mr A on two occasions in July 2025 on the international number he had provided. To illustrate this, Santander pointed me to a separate technical document than the one I placed some weight on in my provisional decision. This shows Santander called the international number once on 23 July 2025 and there was ‘no dial tone’ – not for the 14 July 2025. Having given this further thought, I’m still of the opinion that Santander could have done more knowing what it knew about Mr A’s circumstances and that he was working in a country with in a very different time zone. For example, it could have used its chat function to arrange a best time to call Mr A. So, I don’t think what Santander has said on this point makes a difference. My responses to Santander, as above, otherwise still stand true – so I don’t need to repeat them here. I would however add that I’m persuaded from the plausible and persuasive testimony Mr A has provided, including the chat messages I have seen and that he attempted to establish his son as a power of attorney, that he did travel to the UK solely to resolve his provision of banking. Which included retrieving his funds from Santander before it closed his account. Putting things right To put things right, Santander must:

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- Pay Mr A £750 for the considerable distress and inconvenience it has caused him - Pay Mr A £901.30 for the cost of his flights back to the UK and then returning to work overseas in October 2025 - Provide Mr A with a letter explaining that any adverse credit or loss of benefits he incurred during the period his account was closed was because of its error and this should be rectified by his third-party creditor and/or insurance company My final decision For the reasons above, Santander UK Plc must now put things right as directed above. Under the rules of the Financial Ombudsman Service, I’m required to ask Mr A to accept or reject my decision before 23 April 2026. Ketan Nagla Ombudsman

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