Opening and Keeping a UK Business Bank Account as a Money Service Business

For a UK money service business, the bank account is often harder to get than the registration. Banks can decline without giving a detailed reason, and an account that took months to open can be closed after a periodic review. The firms that get and keep accounts are rarely the ones with the best pitch. They are the ones that can show, with documents, exactly how money moves through the business and who controls it.

This guide is for founders, MLROs, finance leads and CTOs of UK remittance and money service businesses. It covers why banks are cautious, what their due diligence asks for, how to assemble the pack, how to show control of your technology, and what keeps the account open afterwards. It is general guidance, not legal advice; check the current rules with the FCA, your AML supervisor and your advisers.

A bank that holds an MSB's account carries some of that MSB's financial crime risk. Its own regulators expect it to understand its customers' customers well enough to judge that risk. For a remittance business that means thousands of senders and recipients the bank will never meet, money moving across borders, and often cash or corridors the bank considers higher risk.

When a bank cannot get comfortable with that cheaply, the simplest decision is to decline or exit. This is usually called de-risking. It is a business judgement about cost and risk, not a finding that the MSB has done anything wrong. In practice the bank is weighing four questions:

1. Are you properly regulated? Registered or authorised for what you actually do, with a named MLRO.
2. Do you understand your own flows? Who your customers are, where money comes from and goes to, and in what patterns.
3. Do your controls work? Not whether a policy exists, but whether you can show it operating.
4. Will you tell us when things change? New corridors, new owners, new products, problems.

Your job is to make each answer cheap for the bank to verify.

The first thing any bank checks is whether you are allowed to do what you say you do. In the UK, money transmission is a regulated payment service: firms are authorised or registered by the FCA as payment institutions, or operate as an agent of one. Money service businesses must also be supervised for anti-money laundering purposes, by the FCA or HMRC depending on the firm: a firm that only provides money remittance is normally supervised by HMRC. Which applies to you depends on your model, so take advice and be precise about it in the application.

• Apply after, not before. An application that says "registration pending" is far weaker than one with a reference number the bank can look up.
• Describe what you do in the regulator's terms. If your permissions cover money remittance, do not describe the business as "global payments" or "fintech".
• Name your MLRO and their experience. The bank will want to talk to them.
• Explain safeguarding. If you hold customer money, show how it is kept separate and reconciled.

For the difference between authorised and small payment institutions, see API vs SPI: UK FCA requirements, and for the wider picture, UK fintech licensing requirements explained.

Bank onboarding for an MSB usually runs in stages: an initial questionnaire, document requests, follow-up questions and often a call with the MLRO and a director. Expect questions in five areas.

• Ownership and people. Who owns and controls the firm, down to individuals; directors' backgrounds; source of the founders' funds.
• Business model. Products, sending and receiving countries, customer types, delivery methods, expected transaction counts and sizes, how you earn money.
• Flows of funds. How customers pay you, which account receives what, how money reaches payout partners, and how you settle with them.
• Financial crime controls. Risk assessment, customer due diligence, sanctions screening, transaction monitoring, suspicious activity reporting, training.
• Operations and technology. What platform you use, who controls it, where data is held, how it is secured, and what happens if a supplier fails.

The questions are rarely surprising. What sinks applications is inconsistency: projected volumes in the business plan that differ from the questionnaire, a corridor that appears in the risk assessment but not the flow diagram, or a description of the platform that nobody at the firm can explain on a call.

Build a single pack you can send to any bank, and keep it under version control. Each item should come from a source you can refresh, not a one-off document written for this application.

Banks have learnt that an MSB is only as sound as the systems it runs on. Many due diligence questionnaires now include a technology section, and a weak answer ("our provider handles that") is a red flag. The bank wants to know that you, the regulated firm, understand and control the platform your controls depend on.

• Where your data lives and who owns the environment. Be able to say which cloud account holds your production data, in which region, and who pays for and can access it.
• What software you run. A software bill of materials lists every component, so a security reviewer can check for known vulnerabilities without asking you a dozen questions. We cover this in passing a bank or partner security review.
• Who certifies the supplier. If your platform provider holds information security and quality certifications, include the certificates and be clear they belong to the provider, not to you.
• How changes reach production. Releases tested in a staging environment before they touch live money.
• What happens if a supplier fails. Your exit or continuity plan for the platform, payout partners and payment providers.

The firm and numbers here are illustrative, not drawn from any real operator.

A newly registered UK remittance business serves two corridors with bank deposit and cash pickup payouts. It has seven staff, a named MLRO, and runs on a white label platform. Its first application stalls after the bank sends back a follow-up list of 14 questions.

Reviewing the questions, the MLRO sees they cluster into three gaps:

1. Flows. The flow-of-funds diagram showed one account for everything. The bank could not tell customer money from operating money. The firm redraws it with safeguarded customer funds, operating costs and partner settlement shown separately.
2. Screening. The policy said "we screen against sanctions lists". The bank asked which lists, how often and who decides matches. The firm replaces the sentence with the lists it uses, the nightly reload, re-screening when lists change, and a short sample of anonymised match decisions showing who ruled and when.
3. Technology. The bank asked where data is hosted and who controls it. The firm adds its hosting arrangement, the provider's certificates and the software bill of materials.

The second submission answers all 14 questions with documents rather than assurances, and the call with the MLRO is spent on corridors and customer types, not on basic gaps.

Opening the account is the start of the relationship, not the end. Banks review MSB customers periodically and when something unexpected appears in the account. Treat the bank as a stakeholder who needs regular, predictable information.

Two habits matter most. First, never let unexplained money sit in the account: a deposit that matches nothing, a bank recall or a chargeback should be investigated and resolved quickly, with a record. Second, answer the bank's questions with the same data your compliance team uses, so the figures always agree. See matching deposits to the cent and risks that can sink money service businesses.

• Ask what you can. Banks often will not give detailed reasons, but some will say whether the issue was the sector, a corridor or a documentation gap.
• Fix the pack, not the pitch. Review which questions took longest to answer and strengthen those sections first.
• Apply to banks that serve your sector. Some banks and regulated payment providers actively serve MSBs; others do not. A specialist adviser can help you find them.
• Do not hide past declines. Many forms ask; a truthful answer with what you changed is better than an inconsistency found later.

For how this works in another market, see MSB banking in the USA.

RemitSo does not open bank accounts for you. What it gives you is the evidence banks ask for, produced by the platform you run. See the admin features.

• A dedicated AWS account in your region, billed by AWS to your own card: a clear answer to where your data lives and who controls the environment.
• ISO 27001:2022 and ISO 9001:2015 certified: supplier certificates for the technology section of the questionnaire.
• A software bill of materials in CycloneDX format, ready to download: a security reviewer can check components without a long back-and-forth.
• Sanctions screening of every sender and recipient against 8 lists, including the UK Sanctions List, reloaded nightly with re-screening when lists change: specific answers to "which lists, how often, who decides".
• AML rules and 46 risk indicators: limits per transfer, over 90 days and over a year, document tiers as totals grow, and risky transfers held for a person, so your monitoring description matches your configuration.
• Deposits matched to the declared amount, to the cent, with anything unclear held, and chargebacks and bank recalls flagged when they happen: fewer unexplained items in the account.
• Named records for samples: login sessions, rate history, screening decisions, KYC decisions and, where the optional AI assistant add-on is used, its question log.
• Regulatory reports built from transfer data, checked so nothing is left out; today's ready-made report is Australia's IFTI-E.

Your team still owns the bank relationship, the regulatory permissions, the policies, the flow-of-funds design and any UK returns your regulator requires.

See white label pricing, read the getting started guide, or book a demo to walk through the evidence a bank will ask for.

• Payment Services Regulations 2017, regulation 105: access to bank accounts
• FCA: Payment institution applicants
• HMRC Economic Crime Supervision Handbook, ECSH51225: Money service business supervision
• HMRC Economic Crime Supervision Handbook, ECSH41535: when the FCA becomes sole supervisor of a money service business
• FCA: Safeguarding requirements for payment institutions and e-money institutions

Checked October 2026. Regulations change; confirm current requirements with the regulator or your adviser.