Client satisfaction

At Banking Circle S.A. (“Banking Circle”) we are totally committed to delivering the best possible service and to promptly and thoroughly investigate any complaints or questions you may have.

In our capacity as an intermediary payment service provider, Banking Circle processes payment transactions on behalf of our non-bank payment service providers “clients”. Our clients have their own customers, who have no direct relationship with Banking Circle. Banking Circle provides virtual accounts (virtual IBAN), i.e. payment account numbers, under our own bank name, to many of our clients. Our clients assign these virtual accounts, at their discretion, to their own customers account for sending and receiving payments. Note that our clients, not Banking Circle, hold the balances on their own customer accounts. Our clients, or your bank, must first authorise the transaction, and then Banking Circle processes the payment. It is possible that fraudulent transactions, particularly from scam activities, can from time to time, evade both our own and our client’s fraud detection controls.

Banking Circle occasionally receives scam complaints directly from the remitter of the funds paid into a virtual account assigned to a customer who has a direct relationship with one of our clients. We have established a procedure where such a request is forwarded, for investigation and any follow-up action, to our client who had onboarded the beneficiary of the transaction. Once the complaint has been forwarded to our client, Banking Circle promptly informs the complainant of the reasons why the complaint has been forwarded to the client and provides the complainant with the client’s contact details (with the client’s consent) for the further resolution of the complaint.

Working with our client, we will do all we can to help investigate your concerns to help ensure that you have a response on the latest status and list of possible next steps. Please bear in mind that scammers will often quickly withdraw ill-gotten funds so we recommend that claims should be quickly handled through official channels including filing both a police report and a claim directly with your own bank or credit card issuer.

1. Initial step – contact customer service and enquire on status

Prior to filing a complaint, we request that you first visit and make an enquiry into our “Customer Services” team. They will help clarify the situation and may be able to quickly resolve your request.

If you feel that a scam or fraud related crime has occurred and have not already done so, we recommend that you file a police report and also file a claim directly with your own bank or credit card issuer.

If you feel that your issue still was not successfully handled in a timely manner, you have the option to file a complaint with us.

2. Filing a complaint with us if your issue is not resolved quickly

The procedure detailed below will allow us to investigate any dissatisfaction in line with the legal requirements of our regulator – the Luxembourg CSSF (Commission de Surveillance du Secteur Financier). Management oversight of complaints is ensured through regular internal review and reporting.

A complaint can be any written, verbal or electronic communication from a client, a former client or an entity who failed the on-boarding process, to express dissatisfaction and can be submitted free of charge.

If you wish to express your dissatisfaction/complaint, do not hesitate to contact your Client Relationship Manager or any other direct contact within Banking Circle in the first instance.

You can also send your statement to

When contacting Banking Circle with a complaint, please include the following details:

  • Your full name and the name of your company
  • Your role on the account (e.g. accountholder or representative of a client, lawyer etc.)
  • Your contact details
  • Involved account number(s)
  • Information pertaining to the complaint (detailed description of the facts underlying the complaint)
  • Relevant document(s) and/or correspondence
  • Any other detail(s) of relevance regarding your complaint.

If we are not able to provide you with an answer within a short time, an acknowledgement of your complaint will be issued by letter or other durable medium (such as email or fax), within 10 business days from the date of receipt. We will inform you of the contact who will be in charge of the complaint together with an indicative timeline of when a response or resolution will be provided.

We are committed to providing you with a response within one calendar month of receipt of your complaint, by letter or other durable medium (such as email or fax). Where an answer cannot be provided within this period, we will inform you of the delay and the date when the answer is likely to be provided.

If your complaint relates to payments services, we are committed to responding to your complaint by letter or other durable medium (such as email or fax), within 15 business days from the date of receipt.

In exceptional situations, when the response to a complaint relating to payments services cannot be given within said timeframe for reasons beyond our control, we will send you a holding reply indicating the reasons for the delay in responding to your complaint and specifying the deadline for responding (which will not exceed 35 business days).

3. Escalating a complaint

If you have already registered a complaint, as described in steps 1 and 2 above, and you still feel that you did not receive a satisfactory resolution within 15 days, or more if we state a valid reason for the delay, you may appeal directly to our CFO, the person in charge of complaints, who is registered with our regulatory body, the CSSF.

Michael Bo Nørlem Hansen
Chief Financial Officer
2 Boulevard de la Foire
L-1528 Luxembourg

4. Out-of-court resolution of complaints

If, despite our best efforts, you remain dissatisfied with our response or have not received an answer to your complaint within the relevant timeframe (as indicated above), you may refer to the Luxembourg financial regulator according to the provisions of the CSSF Regulation N°16-07 and related CSSF Circular 17/671 relating to the out-of-court resolution of complaints.

Commission de Surveillance du Secteur Financier (CSSF)
283, Route d’Arlon
L-1150 Luxembourg
Postal Address: L-2991 Luxembourg

In order to submit an out-of-court resolution of complaints to the CSSF, you must fulfil the following conditions:

  • You must have sent your complaint previously to the Banking Circle Director in charge of complaints registered with the CSSF, and
  • You must have received no answer or no satisfactory answer from the Banking Circle Director in charge of complaints within the relevant timeframe (as indicated above)
  • You may file your request with the CSSF within one year after the complaint has been filed with the Director in charge of the complaint handling.

Please be informed that your request must be submitted in accordance with CSSF requirements – as stated on the CSSF website and the applicable form.

You may not submit an out-of-court resolution of complaints to the CSSF in the following cases:

  • You have not previously submitted to the relevant professional in accordance with above requirements;
  • The complaint has been previously or is currently being examined by another alternative dispute resolution body, arbitrator, arbitration tribunal or a court, in Luxembourg or abroad;
  • The complaint concerns the business policy of Banking Circle;
  • The complaint concerns a non-financial product or service;
  • The request is unreasonable, frivolous or vexatious;
  • You have not filed the request with the CSSF within one year after the complaint has been filed with Banking Circle.
  • The request handling would seriously impair the efficient functioning of the CSSF.

Once the CSSF has received a request that meets all the conditions, it will transmit a copy thereof to Banking Circle and will ask the Banking Circle Director in charge of complaints to take a position within a period up to one month from the date at which the file was sent. The CSSF will inform you of this transmission.

Within three weeks after receipt of the complete request, the CSSF will inform you and Banking Circle:

  • if it accepts to handle the request or
  • if it is unable to deal with the request (providing detailed explanation of the reason thereof to the involved parties).

Once the request analysis has been completed by the CSSF, it will send to the involved parties a conclusion letter with the reasons for the position taken, namely either:

  • a conclusion letter by the CSSF that the request is partly or totally justified: asking you and Banking Circle to contact each other to settle the dispute in view of the reasoned conclusion and to inform the CSSF of the follow up; or
  • a conclusion letter by the CSSF that the positions of you and Banking Circle are irreconcilable or unverifiable.

In any case, the conclusion reached by the CSSF after the analysis of the request may be different from the order of a court applying legal provisions. Therefore you, as well as Banking Circle, are free to accept or refuse to follow them as the conclusions of the CSSF are not binding.

You, as well as Banking Circle, may also seek remedies through legal proceedings, in particular, if we jointly fail to reach an agreement after the CSSF issues its reasoned conclusion.

Upon proposal of solution by the CSSF, both you as complainant and Banking Circle will have to inform the CSSF whether each party decides to accept, to refuse or to follow the solution proposed by the CSSF within the timeframe defined by the CSSF in its reasoned conclusion letter.

5. Closing of procedure by the CSSF

The CSSF will close the procedure if one of the following occurs:

  • Above situation;
  • The CSSF is informed that an amicable settlement between the involved parties is reached during the procedure;
  • In the case of a written withdrawal of one of the involved parties (written notification to the CSSF and the involved party);
  • Where the right on which the complaint is based is prescribed and where Banking Circle claims that the time period for exercising that right has expired;
  • Where the complaint has been submitted to a Luxembourg or foreign court or arbitrator;
  • Where the complaint has been submitted to an out-of-court complaint resolution body other than the CSSF in Luxembourg or abroad;
  • Where the complainant does not provide the additional documents, information, explanations or positions requested by the CSSF within the period set by the CSSF that cannot exceed three weeks.

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