Just offering some advice for anyone planning to take their complaint to the Financial Ombudsman (FOS), especially around gambling-related transactions or payment disputes.
I’ve dealt with the FOS a lot through my work, and one thing I’ve learned is that your complaint needs to be clear, focused, and take the Ombudsman on a structured journey through what happened. You don’t need to include every single transaction up front, but you do need to explain the key points, supported by your strongest evidence.
Here’s how I would approach it:
1. Make sure you’ve tried to resolve it with the bank first.
FOS will want to see that you’ve raised the issue directly with your bank and that they’ve given you a final response or failed to resolve things after 8 weeks. In your complaint, mention that you attempted to resolve the matter but the bank either dismissed your concerns or put up barriers instead of helping — such as relying solely on time limits, ignoring clear evidence, or failing to investigate properly.
2. Set out a brief, factual summary.
Explain what you’re complaining about — for example, unauthorised or misrepresented gambling transactions, the bank’s refusal to investigate, or the way your case was handled unfairly.
3. Focus on the key issues that matter to FOS:
Unlicensed Gambling Sites: If any of the merchants involved are not licensed by the UK Gambling Commission, then they’re operating illegally under the Gambling Act 2005. Banks should not be allowing these transactions to go through unchecked.
Merchant Misrepresentation: Many gambling sites deliberately use incorrect or misleading Merchant Category Codes (MCCs) to disguise their transactions as retail, software, or other non-gambling services. This misleads both consumers and banks, and your bank has a duty to spot and act on that — not ignore it.
Breach of Credit Card Rules: If you have evidence that these sites advertised or accepted credit card payments, that’s a clear breach of FCA rules (the UK ban on gambling via credit card). Including screenshots or examples can really strengthen your case.
Anti-Money Laundering (AML) Obligations: Banks are legally required to monitor for suspicious transactions, especially involving illegal or high-risk sectors like unregulated gambling. If there were repeated payments to unlawful operators and the bank did nothing, that’s a failure under AML regulations.
Consumer Duty Failings: If your bank appeared unaware of the nature of your transactions, or if things spiralled over time without them stepping in, that may breach the FCA’s Consumer Duty — which requires firms to act in their customers’ best interest and prevent foreseeable harm. It’s worth mentioning if they missed warning signs or ignored patterns of escalating harm.
Misuse of Chargeback Time Limits (e.g. 120 Days): If the bank dismissed your claim on the basis of a strict time limit, explain why that doesn’t fairly apply — especially if you only later realised what the transactions were or discovered that the merchants were acting illegally.
4. Show you have relevant evidence — but don’t overload them at the start.
Let the Ombudsman know that you’re happy to provide evidence such as:
A list of the merchants and transactions
Proof that certain casinos are unlicensed
Screenshots of MCC misrepresentation
Evidence of credit card breaches
Examples where other providers (banks, e-wallets, etc.) investigated or refunded similar claims
5. Be clear about what you want.
Whether it’s a refund, a proper investigation, or for the bank to be held accountable under consumer protection rules, explain what resolution you’re seeking and why.
Final tip: Keep it factual, focused, and fair. The Ombudsman doesn’t need legal arguments — they just need to understand what’s happened, why it wasn’t handled properly, and how you’ve been let down. The stronger and clearer your key points, the better chance you’ll have of getting a fair outcome.