Payment service providers in crypto fraud – Chargeback, liability and reversal
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What fraud victims need to know about payment methods, chargeback rights and the responsibility of payment providers.
Those who have transferred money to a fraudulent trading platform often think it's irretrievably lost. However, the payment method is crucial: depending on whether payment was made by credit card, SEPA transfer, PayPal, or cryptocurrency exchange, completely different recovery options exist. Rogert & Ulbrich examines for victims of fraud what claims they have against payment service providers and how chargebacks can be legally enforced.
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3Which payment service providers play a role in crypto fraud?
With fraudulent trading platforms, money typically flows through several intermediaries. Understanding which service providers were involved is the foundation of any recovery strategy.
Credit card companies like Visa, Mastercard, and American Express are involved in the payment process through the victim's card-issuing bank. They maintain chargeback systems that allow for a reversal of the transaction in cases of proven fraud. These systems function regardless of where the other party is located.
SEPA transfers are processed through the SEPA payment network and the participating banks. Reversals are very limited in time, but possible in individual cases – especially if a SEPA transfer can be treated as an unauthorized direct debit or if the recipient bank cooperates.
E-wallet providers like PayPal, Revolut, or Wise have their own buyer protection mechanisms and internal complaint procedures. However, these often do not apply to purchases classified as financial services or investments.
Cryptocurrency exchanges like Coinbase, Binance, or Kraken are considered payment service providers in a broader sense when cryptocurrencies are transferred to fraudulent wallets via their platforms. Their regulatory obligations – particularly KYC and AML – can form the basis for liability claims.
Can't remember exactly how you made your payment? Rogert & Ulbrich can help reconstruct the payment chain and identify all relevant parties.
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Chargeback for credit card payment
Deadlines, requirements, procedure
Chargeback is the most effective means of reversing credit card payments. It allows for the reversal of a transaction if it can be proven that a payment was fraudulent or that the agreed-upon service was not provided.
The deadline for a chargeback request is usually 120 days from the transaction date, but some card providers allow up to 540 days. This deadline is mandatory – if you miss it, you lose your right to a chargeback. Therefore, act as soon as possible.
The process is handled through the card-issuing bank. The victim describes the fraud in writing, provides evidence – screenshots, communication with the platform, transaction records – and submits the chargeback request. The bank forwards the request to the card network, which in turn contacts the other party. If the other party does not object or cannot provide proof of a legitimate transaction, the amount is refunded.
Banks often initially reject chargeback requests because the facts were not adequately presented or the internal review was unclear. A legally prepared request with a sound legal justification significantly increases the success rate.
Have you made payments by credit card and not yet requested a chargeback? Check immediately if the deadline is still open. Rogert & Ulbrich can assist you with the application process.
SEPA transfer and bank transfer
limited repatriation options
SEPA transfers are significantly more difficult to reverse compared to credit card payments because they are generally considered irrevocable payment orders.
If the money hasn't yet been debited from the recipient's account – which is rarely the case with fast-acting fraudsters – the bank may be able to stop the transaction. In this case, contacting your bank immediately is crucial.
Even if the money has already been transferred, there are still avenues of recourse: If it can be proven that the transfer was induced by fraudulent misrepresentation (Section 123 of the German Civil Code), civil claims for restitution may exist against the recipient bank or the account holder. If the fraud was processed via a German or EU account, prosecution and legal action are more realistic than with non-European accounts.
Furthermore, the bank holding the recipient account may be liable if it ignores warnings of fraud or violates its AML due diligence obligations.
Did you pay by bank transfer? Secure all transaction data and communication. Rogert & Ulbrich will examine which recovery options are available in your specific case.
Liability of payment service providers
when they are partly responsible
Payment service providers are not merely intermediaries. Under certain conditions, they bear their own legal responsibility for damages that arise through their systems.
Under the Payment Services Directive (PSD2) and the German Payment Services Supervision Act (ZAG), payment service providers are obligated to monitor suspicious transactions. As part of their AML (anti-money laundering) compliance, they must identify and report conspicuous payment flows. If a payment service provider demonstrably ignored indications of fraudulent activity – for example, because the same accounts had already been involved in other fraud cases – it may be held jointly liable.
Cryptocurrency exchanges are obligated under the EU Money Transfer Regulation (TFR) and the AMLD guidelines to identify their users (KYC) and report suspicious transactions. If a cryptocurrency exchange fails to block fraudulent accounts despite obvious warning signs, this can form the basis for claims for damages.
These claims are case-specific and require a thorough legal analysis. Rogert & Ulbrich will examine whether liability claims exist against the payment service providers involved in your case.
PayPal, Klarna and e-wallets
Special features and repatriation procedures
E-wallet providers have their own terms of service and buyer protection mechanisms that can be relevant in cases of fraud – but often impose strict limits.
PayPal Buyer Protection generally applies to purchases of goods or services that were not delivered or do not match the description. However, PayPal often rejects Buyer Protection claims for trading platforms, arguing that these are financial services or investments that are excluded from protection. Nevertheless, it is worth trying, ideally combined with a formal complaint that clearly demonstrates the fraudulent nature of the transaction.
Klarna and similar buy-now-pay-later providers have dispute resolution procedures that can intervene in cases of proven fraud. Here, too, documentation of the fraud is crucial.
Revolut, Wise, and similar fintech companies have internal fraud departments that can respond to reports of fraud. Some offer faster response times than traditional banks, but are also bound by their respective terms of service.
Rogert & Ulbrich checks the payment method used and initiates the appropriate complaint and refund procedures.
Legal action against payment service providers
when internal procedures fail
If internal complaint procedures are unsuccessful, legal avenues are available.
Complaints against banks can be filed with BaFin (Federal Financial Supervisory Authority) and with the ombudsman of the Federal Association of German Banks. These out-of-court procedures are cost-effective for consumers and can lead to compensation in certain cases.
If a payment service provider has demonstrably violated its legal obligations – for example, by breaching AML requirements or through faulty payment processing – civil damages can be claimed. This is complex, but economically justifiable in cases of substantial damages.
Rogert & Ulbrich coordinates all relevant procedures in parallel: chargeback application, official complaint, civil lawsuit and criminal complaint are coordinated to maximize the chances of success.
Did you transfer money to a fraudulent platform via a payment service provider and have not been able to resolve the issue internally? Get in touch. Rogert & Ulbrich will examine all remaining options.
FAQs – Frequently Asked Questions about Payment Service Providers in Crypto Fraud Cases
Rogert & Ulbrich – Your lawyers for crypto fraud and payment service provider law
Rogert & Ulbrich is a Düsseldorf-based law firm specializing in cryptocurrency and investment fraud. Dr. Marco Rogert and Tobias Ulbrich represent victims of fraud in recovering funds through all available payment channels – credit card chargebacks, SEPA chargebacks, e-wallet disputes, and cryptocurrency exchange inquiries. With over 40,000 cases handled, the firm has extensive experience in coordinating parallel recovery strategies.
The firm reviews all payment methods used, prepares professionally documented chargebacks, and represents clients in regulatory appeals and civil lawsuits. Rogert & Ulbrich works closely with forensic analysts to ensure complete documentation of payment flows. Many clients have legal expenses insurance that covers attorney and court fees.
Every day counts: Chargeback deadlines are ticking away, and fraudsters are moving funds quickly. Get in touch and secure your claims.

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