Indirect access and banking and payment systems



To become an indirect PSP supported by Royal Bank of Scotland, you will need to establish a banking relationship with us to support your use of our indirect access services.

As with any new customer we must undertake various checks and where you wish to make and receive payments through us, we have specific obligations to follow as a bank.

Identification and validation

A prospective indirect payment service provider must comply with the following requirements upon on-boarding and periodically as it may be required:

  • Cooperate with our endeavour to conduct a satisfactory Know Your Customer (KYC) and Know Your Business (KYB).
  • Evidence of your valid registration with or authorisation by the Financial Conduct Authority (FCA) and any other necessary licensing authority.
  • Your financial status, business model and operating records demonstrating to us your future business viability.
  • Compliance with the Bacs, CHAPS, Faster Payments and Image clearing scheme rules.

Operational procedures and policies

You must have a strong Anti Money Laundering (AML) Policy in place that would also include Terrorist Financing and Anti-Bribery and Corruption. Documented proof of such policy existing may be required in order to verify the existence of at least the following:

  • Robust processes in place to identify and verify your customers and the transactions they will be undertaking.
  • Policy and procedures in place to comply with UK and EU Payment law regulations.
  • Policy and procedures in place for Financial Sanctions and Terrorist Financing (FS&TF) list checking including United Nations, European Union and UK HM Treasury.
  • Controls in place if cash of more than €10,000 is moved into or out of the EU (for high value dealers).
  • Policy and procedures in place to report suspicious activity to the National Crime Agency.
  • Security procedures in place to maintain the security of your customers’ personal information.
  • Records management procedures in place to retain customer information for the appropriate period.
  • Appropriate screening and monitoring of new and existing staff on a periodic basis.
  • Staff training in place on Financial Sanctions and Terrorist Financing, AML, suspicious activity reporting, identifying customers, record keeping requirements.
  • Policy and procedures in place for identifying Politically Exposed Persons.
  • Audit trail of how money is transmitted/received (i.e. the route the money takes in order to get to its destination).
  • Physical security in place to ensure the safety of employees and customers.
  • Procedures to ensure that Royal Bank of Scotland is provided with the outcome of any Money Laundering Audits.

Your procedures for and demonstration of your compliance with all other relevant regulatory requirements e.g. Consumer Credit (CCA) licence, Tax, FCA.

Additional requirements for Sort Code allocation

Where you wish to support your customers to make and receive payments directly from their own accounts, having one or more dedicated sort codes may be necessary.

Royal Bank of Scotland will consider requests for sort code sponsorship from the following organisation types as defined by the Payment Services Regulations 2017:-

  • Authorised payment institutions.
  • Small payment institutions.
  • Electronic money institutions.
  • Credit institutions.
  • The Post Office Limited.
  • The Bank of England.
  • Government departments and local authorities.
  • Registered account information service providers. 

Royal Bank of Scotland will assess the needs of all applicants and their capabilities to operate through a separate sort code and adhere to payment system rules and procedures. In such cases where sort code allocation is not appropriate institutions may still be eligible for banking and payment services from us.

We retain the right (without any liability) to assess both you and your customers’ ability to operate within relevant payment scheme rules and procedures.

Additional requirements for Money Transmitters/Money Services Businesses

In addition to the requirements detail above for PSPs generally and indirect PSPs specifically, you will be able to demonstrate:

  • Policies and procedures in place to comply with SWIFT Scheme Rules, Wire Transfer Regulation (Regulation (EU) 2015/847) and the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (SI 2017/692);
  • Evidence of an independent assessment of your financial crime control environment;
  • Statements of financial performance and assets demonstrating to our satisfaction sufficient income and reserves to maintain a robust control environment;
  • Appropriate screening and monitoring of inbound and outbound transactions.

Forecasted levels of payments, currency account turnover and foreign exchange to be transacted through Royal Bank of Scotland  to determine the commercial sustainability of the relationship. Royal Bank of Scotland will assess the needs of all applicants and their capabilities to operate a money transmission/money service business and maintain financial crime controls in line with Systems and Controls chapter of the Financial Conduct Authority Handbook (SYSC). We retain the right (without any liability) to assess:

  • both you and your customers’ ability to operate within relevant rules and regulations
  • the potential financial crime risk you and your customers pose to the bank and
  • the sustainability of your relationship with the bank in line with its relationship, operational, risk and return expectations.

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