Barclays Corporate eligibility criteria for Non-Bank Payment Service Providers and MSBs

For this criteria to be applicable, you will need to be a client or a prospective client of Barclays Bank PLC/Barclays Corporate Banking or Barclays Bank Ireland PLC (BBI). Please refer to the ring-fencing guidance pages for further information: https://home.barclays/who-we-are/ring-fencing-explained/

Our criteria:

If you are a New to Bank Client, you must have sent us a fully completed ‘New to Bank Questionnaire for Non-Bank Financial Institutions: Fintech and MSBs’. Copies of the questionnaire are available by contacting us or emailing your request to FinTechNewClient@barclays.com.

For these criteria to be applicable, you will need to be a client or a prospective client of Barclays Bank PLC/Barclays Corporate Banking or Barclays Bank Ireland PLC (BBI). 

We will only provide services to clients where our Cross Border Activity requirements and appetite are met.

You will need to be a fully authorised / licenced entity in all of the jurisdictions where you have any activity and evidence of the licences held must be made available to us. Your authorisation will need to be from a Barclays recognised regulator.

You must adhere to our eligibility criteria throughout our relationship and are required to proactively notify us immediately if you identify any shortcomings. If you have applied and been declined a service, you should not reapply within 12 months of the notice of being declined so you have sufficient time to demonstrate that enhancements required to meet our criteria are fully operational and verifiable. 

Your ownership structure needs to be of an acceptable profile to ensure it does not raise concerns regarding financial crime or similar regulatory risks.  You will need to provide us with all requisite information we ask for so we can assess these requirements such as providing evidence to identify and locate ultimate beneficial owners and the source of wealth of their wealth.

We require sight of your strategy and business plan (defining the business model, target client base, geographic catchment and main USPs of the business model) which all must be acceptable to Barclays. This business plan should also highlight if you undertake business activity through intermediaries (such as Agents) and give details of these arrangements. In reviewing we will consider whether your activities or those of your customers include areas where we have limited commercial and reputational risk appetite such as sectors like Crypto Asset Exchanges & Custodian Wallet Providers or non-financial services regulated money transfer businesses. Given the fluctuating climate we operate in we can provide you with further detail of such areas on request.

Your financial position must meet Barclays commercial risk appetite and in considering your overall financial position we will consider relevant factors, of which the following are indicative examples of the types of evidence we will consider:

• Copies of your financial statements: These will need to be audited and unqualified.
• Capital Adequacy: We require evidence that you maintain a robust capital base that complies with regulatory requirements and provides a cushion against potential financial stress.
• Asset Quality: We will examine the asset portfolio to ensure it mainly comprises high-quality, liquid, and low-risk assets.
• Sufficiency of Liquidity: We will need evidence that you have sufficient liquid assets to cover liabilities as they fall due. This includes holding cash reserves and having access to liquid financial instruments that can be quickly converted into cash without significant loss.

You must meet our commercial eligibility criteria, meaning our minimum revenue thresholds (or pay any fees that address any gap against minimum revenues) and commercial appetite for us to assess suitability for services sought and to assess significance to the market, impacts on payment system settlement values and our respective risks and liabilities. Our commercial eligibility criteria may change from time to time.  These will also be used to assess capacity requirements, operational impacts and risks and to determine applicable charges. 

You should have an acceptable reputation in the marketplace. As part of this assessment, amongst other considerations, we will evaluate your organisation’s compliance with regulatory frameworks, considering in particular any history of fines, sanctions, or enforcement actions by regulatory or governmental bodies. Additionally, we will review any previous or ongoing criminal proceedings, any previous or ongoing civil proceedings directly related to regulatory breaches, financial crime systems and controls, market abuse, repeated violations of industry standards, or other significant compliance matters. You must comply with any applicable rules of a relevant domestic or international payment system and your operations should not cause us to contravene any applicable rules of a relevant domestic or international payment system. We may also consider the nature and frequency of customer complaints.

Your senior management and leadership team needs to be appropriately qualified and experienced in the specific business areas and activity undertaken by the company.

You must have a suitably qualified and experienced Money Laundering Reporting Officer (MLRO) who is wholly independent from any revenue generating function of the business.

You must have robust systems and controls in place to segregate any client funds you hold from your own company cash flows. You must return a signed copy of the Attestation on Disclosures relating to Safeguarding Accounts Barclays issues upon initial review and at every cyclical review.

Any technology platforms used should be fit and proper for their intended use, especially where they are deployed to mitigate AML risk.

You need to be able to demonstrate a risk based approach evidenced in your organisation’s culture including evidenced management and leadership oversight of AML and compliance programs. 

You will need to be able to demonstrate and evidence Financial Crime and Fraud Prevention Capabilities (including, but not necessarily limited to, robust AML & Sanctions policies and procedures, transaction monitoring, sanctions screening, robust client on-boarding processes & procedures and strong agent or other intermediary program control and oversight) aligned to your business model and supported by appropriate technology. You will need to be able to meet financial obligations on you arising from financial crime and fraud prevention measures and also have the processes to meet obligations arising out of these such as APP Fraud Reimbursement requirements. You must provide a copy of your key policies and procedures as well as a report and testing reviewing these capabilities. This report must be carried out by a qualified independent external body (from our preferred list) prior to on-boarding and at least annually thereafter. This report together with full management responses to be made available for Barclays to review. The report will need to be sourced by you and cost of this report is also borne by you. Our mandatory scope for such report is available on request. Please note that we may not be able to accept reports which do not fully cover the set minimum scope or are completed by firms outside the preferred list.

You must be able to qualify the specific risks posed by your underlying client base and operating model, and these risks must be sufficiently mitigated through policies, processes, procedures and use of appropriate technology.

You must immediately contact us if you currently conduct or plan to conduct operations or provide services in/to industries that are outside or limited by our reputational or industry risk appetite. This list can be provided on request. If you operate in or provide services to industries that are outside our reputational or industry appetite or tolerance, we may restrict services we can provide to you either partially or fully.

We will not be able to provide banking services to support activity in any underlying client industry which is illegal in any of the jurisdictions within which we operate even if they may be legal elsewhere e.g. recreational drugs.

The risk profile of jurisdictions where you receive flow of funds from and where you may be sending funds to, must be assessed acceptable to Barclays and we may not be able to support certain jurisdictions we have assessed as High Risk.

We consider the provision of services to other Payment Service Providers as a high risk underlying industry. Additional Due Diligence assessing the specialist controls and due diligence applied by you to these underlying clients will be required. We may not be able to support such flows whether partially or fully. The materiality of such flows (both on a standalone basis and as a proportion of your overall flows) may also impact our overall ability to provide corporate banking services to you.

If you are a member of SWIFT and have RMAs exchanged with Barclays, you will be required to be compliant with the SWIFT Client Security Programme (CSP) Mandatory Controls. You must provide a copy of your current attestation to evidence compliance or grant Barclays access to your attestation on the SWIFT Registry to view your Attestation.

The banking product range required needs to be established and explained fully. Depending on your business model, we may not be able to make all of our products available to you, whilst certain products /services may require further specific due diligence to be completed before they can be made available. Additional requirements for any Agency Banking arrangements are applicable.