In line with our obligations under Regulation 105 of the Payment Services Regulations 2017, we will conduct a Proportionate, Objective and Non-Discriminatory (POND) assessment of all applicants to Starling Banking Services.

In order to submit an application, you will first need to meet the eligibility criteria. Following that, in order to successfully open an account you will also need to meet our assessment criteria to a satisfactory level.

Eligibility criteria

To be eligible to apply for indirect access services via Starling Banking Services you must meet the following criteria:

  • You will need to be a Starling Bank customer, i.e. you will need to establish a banking relationship with us to support your use of our indirect access services. You will therefore need to meet our risk-based assessment criteria outlined below.
  • You must be a Payment Service Provider domiciled and regulated in the UK or EEA and authorised to offer financial services within the UK. A “Payment Service Provider” comprises the following (as defined in the Payment Services Regulations 2017):
    • Authorised payment institutions;
    • Small payment institutions;
    • Registered account information service providers;
    • EEA authorised payment institutions;
    • Electronic money institutions, including branches located in the EEA;
    • Credit institutions, including branches located in the EEA;
    • The Post Office Limited;
    • Government departments and local authorities;
    • Any person who has made an application to the FCA or the relevant competent authority in their home EEA state to be authorised or registered as any of the Payment Service Providers listed above.

Assessment criteria

  • You must have a robust financial crime framework in place, which includes Anti Money Laundering (AML), Terrorist Financing and Anti-Bribery and Corruption controls. An assessment of such will be conducted by our supplier.
  • You must be able to demonstrate your future business viability, financial status and business model.
  • You must not be engaged, or have customers who are engaged in the following industries;
    • Adult entertainment, products or services;
    • Gambling;
    • Money Transmission services, where the originator or recipient of the payment is unclear;
    • Act as a wholesaler to cash-based money remitters;
    • Offer downstream services to other PSPs beyond your original customer; or
    • Cryptocurrencies.
  • You must comply with all applicable laws, including industry best practice guidance and scheme rules.
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