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01 · FIRM PROFILES

Financial crime risk by business model

Select a firm type to see its inherent risk matrix, regulatory obligations, applicable typologies, and suggested controls.

Neobank / Digital Bank

App-only bank with fast remote onboarding and rapid customer growth.

A neobank delivers current accounts, cards, instant payments and increasingly lending entirely through an app, with fully remote onboarding and very fast growth. The combination of frictionless onboarding, instant rails and scale means financial-crime controls must keep pace with customer numbers, which is where the model is most often tested.

17typologies
4risk themes
1FCA cases
Services, products, customers & market examples

Holds a banking licence (PRA and FCA) or operates on an e-money permission, with AML obligations under the Money Laundering Regulations 2017.

Typical services

App-based current accounts and cardsInstant domestic and faster paymentsSavings, overdrafts and consumer lendingIn-app foreign exchange and travel spend

Products

E-Money AccountsCard IssuingDomestic PaymentsCross-Border PaymentsLendingFX Transfers

Primary customers

IndividualsSMEs

In the market

Monzo

App-only UK current accounts, cards and instant payments.

Starling

Digital bank for personal and small-business banking.

Revolut

Multi-product app spanning accounts, cards, FX and crypto.

Chime

US app-based banking through partner-bank rails.

Named firms illustrate the business model only. They show what an archetype looks like in the real market and are not an allegation of any control weakness or wrongdoing.

Where the risk concentrates

Typologies for a Neobank / Digital Bank (17)