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).