Open banking is the use of open APIs that enable third-party developers to build applications and services around financial institutions. Tink provides services in the open banking industry and therefore offers services that rely on interactions with financial institutions. Our services are provided on a software-as-a-service basis and all use is governed by the terms of our Master Service Agreement.
Some open banking activities require a license or authorization under open banking legislation. Tink's platform can be configured to support both licensed and non-licensed customers and consequently, understanding the licensing configuration is important as it has legal implications. Here are some key differences that depend on licensing:
Licensed customers - Tink operates as a technical service provider when provisioning services to licensed customers and contracts with its customers like in a normal customer-vendor relationship.
Non-licensed customers - Our customers redirect end-users to Tink, who then offers services that are subject to licensing requirements directly to the end-users, after which the end-users are redirected back to the customer. Our services to our customers are governed by the Master Service Agreement and our services to end-users are governed by our End-User Terms of Service.
Want to know more about open banking or deep dive into the different terms and industry parties? You'll find more information in these resources:
Tink may provide its services through agents. Agents are Tink's customers that have been appointed to provide Tink's services. Please contact us if you would like to explore options.
Tink AB is an authorised payment institution licensed and regulated by the Swedish Financial Supervisory Authority (Swe. Finansinspektionen) (SFSA ID: 44059) to provide account information services (AIS) and payment initiation services (PIS) in the EEA.
Tink Germany GmbH is an authorised payment institution licensed and regulated by the Federal Financial Supervisory Authority (Ger. BaFin) (BaFin-ID: 10152149), under the laws of the Federal Republic of Germany to provide AIS and PIS in the EEA.
Tink Financial Services Limited is an authorised payment institution licensed and regulated by the UK Financial Conduct Authority (FRN: 988456) to provide AIS and PIS in the UK.
Tink is therefore subject to requirements in a number of anti money laundering and counter terrorist financing legislative acts (AML/CTF framework).
When Tink is providing services on its license, we enter into a business agreement with you as set out in the AML/CTF framework. This means that Tink needs to perform customer due diligence on you (as a part of Know Your Customer rules). We also perform sanction- and PEP-screenings.
No, you can't. If you don't complete the onboarding form and provide the requested information, Tink will not be able to provide services for you.
The AML-framework is risk based. Tink's mitigating measures in place, to handle the AML/TF-risk that we are exposed to, should be adequate to the level of risk. When assessing the AML/TF-risk, Tink is obliged to take into consideration certain factors such as for example certain geographical aspects and what operational areas the customer is active in. If a customer relationship imposes higher risks, Tink will as a standard impose a lower PIS-limit to meet the increased risk.
We provide either account information services or payment information services to the payment service users (end-users). These are governed by our End-User Terms of Service.
When Tink operates as a payment service provider, the regulations require that explicit consent is obtained from the payment service users (end-users) before providing payment services to them. The explicit consent is a contractual consent which Tink obtains when the payment service user interacts with us in Tink Link.
Note that the explicit consent referred to in PSD2 is separate from the legal bases stipulated in the GDPR and that Tink does not use consent as a legal basis under the GDPR.
Tink AB is an authorised payment institution licensed and regulated by the Swedish Financial Supervisory Authority (Swe. Finansinspektionen) (SFSA ID: 44059) to provide account information services (AIS) and payment initiation services (PIS) in the EEA.
Tink Germany GmbH is an authorised payment institution licensed and regulated by the Federal Financial Supervisory Authority (Ger. BaFin) (BaFin-ID: 10152149), under the laws of the Federal Republic of Germany to provide AIS and PIS in the EEA.
Tink Financial Services Limited is an authorised payment institution licensed and regulated by the UK Financial Conduct Authority (FRN:988456) to provide AIS and PIS in the UK.
Note that Tink's licenses do not cover activities carried out by our customers or partners.
For Tink AB, please visit SFSA's Company Register or EBA’s Payment Institutions Register.
For Tink Germany GmbH, please visit BaFin Company database or EBA’s Payment Institutions Register.
For Tink Financial Services Limited, please visit FCA’s Financial Services Register.
Tink AB holds a Swedish license and Tink Germany GmbH holds a German license. In other EU-markets, these entities provide their services as cross-border services under an EU passport.
The SFSA's Company Register, the BaFin Company database and EBA’s Payment Institutions Register (please see links above) show to which markets these Tink entities have the right to provide cross-border services.
Tink Financial Services Limited holds an English license and provides its services in the UK.
Some major differences:
It is the licensed party that formally is the provider of the payment service (AIS and/or PIS).
It is the licensed party that identifies itself towards the bank when accessing the end-user's accounts.
It is the licensed party that has the relationship with the end-user, meaning that it is that entity’s terms and conditions and privacy notice that is displayed towards the end-user.
The end-user gives its explicit consent to be provided with the service to the provider of the service.
The licensed party carries the regulatory risk for the service, including to comply with AML obligations for the payment service.
Tink does not allow unlicensed customers to white label Tink Link.
While the look and feel of Tink Link can be somewhat customized within our services (subject to certain regulatory requirements), we may only permit licensed customers to fully white label Tink Link as we use Tink Link to ensure that we meet our regulatory requirements when provisioning services to payment service users (or end-users).
Tink AB is a Payment Institution authorised and regulated by the Swedish Financial Supervisory Authority (SFSA) and Tink Financial Services Limited (TFSL) is a Payment Institution authorised and regulated by the UK Financial Conduct Authority (FCA) to provide Account Information Services (AIS) and Payment Initiation Services (PIS) in the EEA and UK. Tink has partnered with two Financial Institutions to offer Tink’s Settlement product to our customers. This product is offered in partnership with Modulr FS Limited and Modulr Finance B.V. (“Modulr”), and The Currency Cloud Limited (“Currencycloud”). Tink’s relationship with these partners, and the services we provide in partnership with them, are further described below. Please note that AIS and PIS services provided by Tink AB and TFSL are separate and unrelated to the payment and e-money services you receive from our partners.
Tink AB is a distributor of Modulr FS Limited, a company registered in England and Wales with company number 09897919, which is authorised and regulated by the Financial Conduct Authority as an Electronic Money Institution (Firm Reference Number: 900573) for the issuance of electronic money and payment services. Settlements accounts1 and the related services are provided by Modulr FS Limited. Whilst Electronic Money products are not covered by the Financial Services Compensation Scheme (FSCS) your funds will be held in one or more segregated accounts and safeguarded in line with the Electronic Money Regulations 2011 – for more information on safeguarding please visit Modulr’s website with information about safeguarding.
Tink AB is a partner of Modulr Finance B.V., a company registered in the Netherlands with company number 81852401, which is authorized and regulated by the Dutch Central Bank (DNB) as an Electronic Money Institution (Firm Reference Number: R182870) for the issuance of electronic money and payment services. Settlement accounts 2 and the related payment services are provided by Modulr Finance B.V. Your funds will be held in one or more segregated accounts and safeguarded in line with the Financial Supervision Act (Wet op het Financieel Toezicht, Wft) – for more information on safeguarding please visit Modulr’s website with information about safeguarding.
Tink Financial Services Limited is a partner of The Currency Cloud Limited (“Currencycloud”) for the provision of payment and e-money services in the United Kingdom. The Currency Cloud Limited is a company registered in England with company number 06323311 and having its registered office at Stewardship Building 1st Floor, 12 Steward Street London E1 6FQ. The Currency Cloud Limited is authorized and regulated by the Financial Conduct Authority under the Electronic Money Regulations 2011 for the issuing of electronic money (Firm Reference Number: 900199); Currencycloud’s terms of use can be found on Currencycloud’s website.
When funds are posted to your account, e-money is issued in exchange for these funds, by our partner Currencycloud which is an authorised Electronic Money Institution. In line with regulatory requirements, Currencycloud safeguards your funds. This means that the money behind the balance you see in your account is held at a reputable bank, and most importantly, is protected for you in the event of Currencycloud’s, or our, insolvency (except for the costs of distributing the asset pool in the event Currencycloud’s insolvency). Currencycloud stops safeguarding your funds when the money has been paid out of your account to your beneficiary’s account.
We are your first port of call for any queries or concerns, including complaints. We will handle these complaints in line with our complaints process. You can find information on Tink’s complaints handling process and how to contact us here. We work with Currencycloud, who ultimately provides you with regulated payments and e-money services for parts of our Settlement product. Currencycloud has certain obligations as a regulated financial services institution, including around complaints. We keep them informed of the complaints we receive from you regarding the regulated payments and e-money services they ultimately provide to you. They oversee how we handle complaints to ensure we do this to the standard required under the regulations. However, if for any reason your complaint regarding your payments and e-money services has not been acknowledged or dealt with by us, or if you have concerns about the way it has been handled, Currencycloud’s complaints information can be found here.