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ASA Ruling on Transferwise Ltd

Transferwise Ltd

N1 7BA


5 February 2014


Internet (on own site)



Number of complaints:




Complaint Ref:



TransferWise Ltd is authorised by the Financial Conduct Authority (FCA) for the provision of payment services.  As of 22 July 2016, complaints about misleading advertising for such services will be referred to the FCA for their consideration.


A website for a company that offered foreign currency transfers, included a graph that compared the "True cost of sending 10,000 GBP to EUR" between the advertisers and three competitors.  Text above the graph stated "Many banks take as much as 5% of the amount you're sending. TransferWise charges just half-a-percent". The graph was headed "Real transfer fee" and showed the fee for sending £10,000 with TransferWise was £50 and to send the same amount with Moneycorp cost £182.  Text below the graph stated, "Calculations based on a mid-market GBP EUR exchange rate of 1.185".


Moneycorp challenged whether the ad misleadingly implied that the "Real transfer fee" related to the transactional transfer fee only, because they understood the fee was also based on different exchange rates offered by different providers.

CAP Code (Edition 12)


Transferwise Ltd said that traditional providers charged two different fees on international money transfers: stated fees (transactional transfer fees), which were presented to the customer before making the transaction; and the exchange rate mark-up, which was the difference between the real mid-market exchange rate at the time of the transaction and the rate offered to the customer. They said the "Real transfer fee" was the sum total of those two fees. They explained that the "Real transfer fee" stated for Moneycorp Ltd was based on a mystery shopper exercise.



The ASA understood that the "Real transfer fee" did not relate to the transactional transfer fee only. Rather, it was the sum total of the transactional transfer fee and the exchange rate mark-up. In the absence of a qualification to explain how the "Real transfer fee" had been calculated, we considered that the reference to the "Real transfer fee" was ambiguous and that consumers could understand the ad to mean that the "Real transfer fee" related to the transactional transfer fee only. Because we understood the "Real transfer fee" was based on different exchange rates offered by different providers, in addition to the transactional transfer fee, and because the ad did not make that clear, we concluded that the presentation of the ad was likely to mislead.

The ad breached CAP Code (Edition 12) rules 3.1 and 3.3 (Misleading advertising) and 3.33 (Comparisons).


The ad must not appear again in its current form. We told Transferwise Ltd to ensure ads were not likely to mislead in future.

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For advice and training on the Advertising Codes please visit the CAP website.

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