Eligibility Criteria for UK/EEA Non-Bank Payment Service Providers


The purpose of this eligibility criteria is to provide transparency to prospect clients regarding the minimum standards required to proceed with onboarding.

In addition, any assessment of UK/EEA Non-Bank Payment Service Providers (“NBPSP”) is performed in accordance with the law as defined under PSD2’s Article 36, and local equivalents and implementation.

Non-Bank Payment Service Providers include Payment Institutions and Electronic Money Institutions (small or otherwise). This also includes firms who are applying for authorisation for permissions / licences.

All assessments are undertaken on a proportionate, objective and non-discriminatory (POND) basis. To be eligible to receive services, a NBPSP must meet the criteria detailed below.

Additionally, due to limitation imposed by our UK license, we will not accept applicants that fall within the classification of a micro-enterprise, as defined by the UK Payment Services Regulations 2017, FCA guidelines, and PSD2 directives, which specifically pertain to entities employing fewer than 10 persons and with an annual turnover and/or balance sheet total not exceeding EUR 2 million.

Eligibility Criteria

The applicant must:

  • Complete and return the ‘Banking Circle Initial Client Questionnaire’ (BCICQ)
  • Be either authorised in the jurisdictions where the firm has activity, or, be in the final stages of the process of applying for authorisation (final stages means that the majority of the documentation has been provided to the relevant Competent Authority and there is evidence they have responded positively, for example the firm has received a “minded to” approve letter
  • Meet minimum revenue thresholds (or pay minimum fees)
  • Complete Banking Circle’s Safeguarding letter, if safeguarding accounts are required
  • Comply with all applicable laws and conduct requirements
  • Have a profile that is of an acceptable standard to Banking Circle, which includes (but is not limited to) Banking Circle reviewing the:
      • Ownership structure (Shareholder Transcripts and Group Chart), including identification and locations of Ultimate Beneficial Owners
      • Evidenced Source of Wealth of the Ultimate Beneficial Owners
      • Experience of the senior management and leadership team (must be of an acceptable risk profile)
      • Description of the firms’ nature of business and an explanation of the services you provide to customers – for example through any Business Model / Plan / Strategy documentation
      • Risk profile of the firms client base, payment flows, and geographical exposures (these must be within Banking Circles Risk Appetite available here)
      • Annual payment volumes and aggregate payment values
      • Reputation of the firm (any open adverse media to be assessed)
      • Financial profile of the firm (including capital adequacy / the firm being able to meet its current and future liquidity and funding requirements)
  • Have acceptable Financial Crime Framework and Prevention Capabilities (this includes Anti-Money Laundering (AML), Counter Terrorist Financing (CTF) and Anti-Bribery and Corruption (ABC) controls). These must be of an acceptable profile to Banking Circle, which includes (but is not limited to) Banking Circle reviewing the:
      • Enterprise-wide Inherent Risk Assessment for Anti-Money Laundering and Counter Terrorist Financing
      • Governance Structure, (which should demonstrate clear reporting lines, the understanding of the distinction between 1st and 2nd line roles and responsibilities, and the oversight of Compliance and AML/CTF teams by management)
      • Experience and qualifications of the MLRO, Compliance team and Onboarding team. (These persons must not have any conflicts of interest, for example they should be independent of any income generating departments)
      • Key Policies and Procedures detailing the firms risk mitigation processes
      • Customer risk rating methodology
      • Client Due Diligence and Ongoing Due Diligence processes (including Source of Wealth checks)
      • Transaction Monitoring systems and processes
      • PEP and Sanctions screening
      • AML/CFT Training program
      • SAR/STR filing and reporting processes
      • Investment in appropriate systems for the Client Due Diligence and ongoing Due Diligence processes (examples include screening tools, risk calculators, databases, etc.)
      • Outsourcing partners and any third parties involved, if applicable
      • Results of any independent AML reviews/audits that the firm may have (this review is at the both the beginning of the relationship and ongoing). If no independent AML controls reviews/audits have taken place, the Compliance officer must confirm this, and Banking Circle will undertake its own review of the firm’s Financial Crime Framework and Prevention Capabilities
  • Have satisfactory records management procedures to retain customer information and the ability to provide Banking Circle any relevant information it may require (for example transaction information, or customer due diligence records).
  • Not be a micro-enterprise which employs fewer than 10 persons and has a turnover or annual balance sheet that does not exceed €2 million euros.

Information Required

The information that will be required from each applicant can be found in our BCICQ, the Client Application Form and a document that Banking Circle provides as part of its application process that lists all of the documents needed to be submitted as part of the application. All of these are available upon request.

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