Working with Starling Banking Services (SBS)

Starling Banking Services supports a wide range of payment firms, from start-ups to established businesses, covering diverse business types in varied industries. We have a clear risk criteria that we use to assess all our potential relationships.

Who we work with

• We only work with financial institutions who are domiciled, licensed, registered or regulated in the UK. We will work with clients who are in the process of getting regulated in the UK but we don’t currently offer an agent model for unregulated businesses.

• We facilitate payments for a wide range of industries but we can’t support payments relating to the following activities, and also will not onboard clients who have a significant business in these areas.

  • Gambling or betting (including the establishment or operation of lotteries or competitions).
  • Pornography, adult entertainment, dating or escort services.
  • Defence or weapons (including manufacturing and/or distribution of weapons, explosives or armaments).
  • Cryptocurrencies (e.g. Bitcoin) or virtual currencies.
  • Money Transmission Services where there is significant exposure to High Risk Third Countries.
  • Wholesalers to cash based money remitters.
  • Activities undertaken by unregistered or unregulated charities.
  • Political parties.

• We will also consider the Bank’s social and ethical positions, for instance the Bank’s Carbon Reduction Plan and Ethics Statement, as part of our new client application process.

• We will perform regulatory and adverse media checks and may decide not to onboard a client with significant recent issues.

Assessing financial crime risk and controls

As a regulated Bank, we take our financial crime responsibilities very seriously. Reviewing a client’s financial crime management will be a key part of both onboarding and ongoing assessment.

• We will only support clients who have robust financial crime risk controls, including sanction screening. We won’t support entities or individuals engaged or suspected to be engaged in unlawful activities.
• We have no appetite for facilitating transactions with sanctioned individuals or entities and we will not tolerate regulatory or sanction breaches.
• We will not work with clients that expose Starling to Authorised Push Payment liability.
• We will not work with firms that have an unclear ownership structure.
• We have a conservative approach to business types which are inherently higher risk for money laundering and will increase the level of due diligence undertaken both at onboarding and on an ongoing basis to gain assurance that this risk is being managed appropriately.