Offering banking services is a complex business, with high potential for fraud, money laundering etc. That’s why a license is required. Swan has an e-money license overseen by the ACPR (Autorité de Contrôle Prudentiel et Résolution), which is valid across the European Economic Area (EEA). Learn more here. Getting licensed as a Financial Institution is a tedious process. It takes a lot of time, effort, and money. That’s why we got our own license - so you don't have to - and we designed our product in a way that doesn’t require you to become a regulated agent. To make this possible, we must make sure to never delegate any risky/sensitive banking operations to you.
To ensure that we do not delegate any risk to you, we must have a direct relationship with your customers (the end-users of the banking product). Amongst other things, this direct relationship (Swan↔your customers) will be used during the KYC process and the Strong Customer Authentication process.
Your customers will use your product to access their Swan accounts. Swan will regularly audit your behavior in this relationship (You↔your customers), to make sure the rules are being respected. You are allowed to make your customers pay for access to your platform. On top of this, you are allowed to make customers pay for the banking services themselves. Learn more here.
When your customer opens an account with Swan they must accept Swan's Terms and Conditions, which they will receive by email. Within the T&C we mention Swan’s Web Banking, but since you may or may not choose to provide it to your customers, we won’t otherwise market Swan’s Web Banking to your customer.
As defined in the Terms and Conditions, your customer allows some tasks to be delegated to you :
Consultation of the Account and the Electronic Money Account;
Transmission of information to Swan for the opening of the Account or Electronic Money Account;
Preparation of Card orders;
Preparation of transfer orders;
Preparation of internal direct debits for which the creditor is the End Customer and for which the debtors are other end customers of Swan;
Invalidation of transfers, direct debits, or Card payments;
Preparation of electronic money loading by credit card;
Preparation of the reimbursement of the balance of the Electronic Money Account;
Transmission of requests to contest payment transactions;
Your customer can be charged by Swan or by yourself depending on your marketing perspective. More details here.
When you present Swan's banking services to your customers, Swan handles the most sensitive banking operations. We don't delegate them to you. But you may still perform all the tasks listed above. In this relationship, Swan charges you a flat base fee, as well as fees per account and per card. See our standard pricing. There are two possible legal statuses for a company offering banking services via Swan. More on this in the next article.