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) or EEA passported licence, 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 RBS 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.
RBS 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.
- EEA authorised payment institutions.
- Electronic money institutions.
- Credit institutions.
- The Post Office Limited.
- The Bank of England, the European Central Bank and the national central banks of EEA States other than the United Kingdom.
- Government departments and local authorities.
- Registered account information service providers.
- EEA registered account information service providers.
RBS 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.