Guidelines
Your legal status while partnering with Swan depends on the country your company is based in.
You will operate as a Commercial Agent of Swan. There is no regulatory process required to become a Commercial Agent, we will handle it once you go live.
You will operate as a Registered Swan Intermediary (MOBSP : Mandataire en Opération de Banque et en Service de Paiement). Companies with MOBSP status are regulated by l'ORIAS. Discover the step-by-step process
Here's what you can do:
- 1.Present payment services directly on your platform. You won't have to route your end-users to Swan
- 2.Provide access to your own platform, app, or SaaS, where end-users can manage their Swan accounts, prepare payment orders, etc.
- 3.White-labeled branding. You can brand our payment services as your own, simply mentioning Swan as a partner in your T&C
- 4.Mention Swan's T&C in your own T&C
- 5.Collect client information and KYC documents yourself, then forward them to Swan. Just make sure to specify this in your GDPR notice to your clients (Proof of Address, Company Registration documents, etc.)
Restrictions:
- 1.You may not manage sensitive operations yourself (e.g. KYC, Strong Customer Authentication) although you may participate in collecting required documentation.
- 2.You may not call yourself a bank or a neobank. Regulations stipulate that companies with your legal status may not declare themselves a bank nor a neobank.
- 3.You may not sell payment services. Only Swan is allowed to sell payment services. You may only present them.
- 4.You may not call your offer a “bank account” or a “payment account”. Only Swan provides a payment account. Here are some alternatives you may use: “MyBrand Account,” ‘MyBrand Premium,” or “MyBrand Wallet”.
As a partner, you are allowed to sell and present Swan's commercial offer as your own, without any obligation to mention Swan. To comply with data protection regulations, your company must:
- 1.Provide its own privacy policy
- 2.Indicate to customers that their data will be shared with Swan
- 3.Indicate the company’s legal status. Make sure to provide the following in your footer and/or legal notices:
- The name of your status (“MOBSP” for French companies, “commercial agent” for companies outside of France)
- Your Orias registration number if indicated
- Legal name as provided
- Postal address
You are authorized to present Swan's T&C within your own T&C or directly on your website.
You are authorized to present Swan's commercial offer within your own T&C or on your website as well.
Because Swan is a financial institution supervised by the Banque de France, we have a regulatory requirement to verify the identity of our customers. Your customers will often verify their identity through a short video of their face, which is a great way for Swan to prevent fraud.
Swan processes and stores these videos with great care. Videos are encrypted in our systems and stored in European data centers. Your customers' data is never transferred outside of Europe. Additionally, Swan's internal access to your customers' videos is limited to teams verifying identities and teams in charge of compliance with banking regulations.
Swan is required by law to keep data for five years after the closure of the customers' account, in accordance with French banking regulations.
We have a new and improved page with more details on our country coverage here: