Indirect Access to UK Payment Systems

To become an indirect PSP, supported by Ulster Bank, you’ll need 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 if you wish to make and receive payments through us we have specific obligations to follow as your bank.

A prospective indirect payment service provider or money service business provider must comply with the following requirements when opening an account, and periodically as required: 

• Cooperate with our requirement 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 passport 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, Cheque and Credit Clearing scheme rules

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

• Robust processes to identify and verify your customers and the transactions they will be making; 
• Policy and procedures to comply with UK and EU Payment law regulations; 
• Policy and procedures 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; 
• Policy and procedures to report suspicious activity to the National Crime Agency; 
• Security procedures to maintain the security of your customers’ personal information; 
• Records management procedures to retain customer information for the appropriate period; 
• Appropriate screening and monitoring of new and existing staff on a periodic basis; 
• Staff training on Financial Sanctions and Terrorist Financing, AML, suspicious activity reporting, identifying customers, record keeping requirements; 
• Policy and procedures for identifying Politically Exposed Persons; 
• Audit trail of how money is sent/received (i.e. the route the money takes to get to its destination); 
• Physical security in place to ensure the safety of employees and customers; 
• Procedures to ensure that NatWest 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. 

In addition to the requirements detailed above for PSPs, you must 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 Ulster Bank to determine the commercial sustainability of the relationship. Ulster Bank 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 risks 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. 

We can sponsor Indirect PSPs into the following UK payment systems: 

• Bacs - Bulk payments (Direct Credit) and collections (Direct Debit) 
• CHAPS – High value – same day payments 
• Faster Payments – 24x7 near real-time payments 
• Image Clearing System 

The Terms and Conditions that will apply to Indirect PSPs depends on the specific products and services selected. These will include: 

1. Account Terms for Credit Institutions, Credit Unions and other Payment Service Providers 
2. Indirect Access to Payment Services contract 
3. Optional Product Specific Terms and Conditions

 
We’ll agree the applicable charges with you for banking and Indirect Access services and we’ll confirm these in writing before we open your bank account(s). Charges for additional services will be advised in writing before use. As an Indirect PSP you should expect charges for:

• Set-up and access to submission channels (including setup, maintenance, security credentials) 
• Operation and funding of your bank account(s) 
• Payments you send and receive 
• Advice of transactions (per transaction and file charges) 
• Other products and services that you’ve requested