Banking Circle 2025: The Payments Bank Whose Largest Fee Line Is Not Payments An EFRI financial-structure analysis based on Banking Circle S.A.’s audited financial statements for 2022–2025, its regulatory disclosures and its own product descriptions. It makes no finding of criminal or regulatory misconduct. Where the accounts do not permit
Banking Circle’s vIBAN Model in Practice: Kraken, Bano and the Look-Through Problem EFRI has repeatedly argued that the principal risk of virtual IBAN structures is not the IBAN itself. It is the separation between the bank whose name appears in the payment chain, the regulated intermediary that is the bank’s
The EBA’s May 2024 report confirms there is no legal definition of “virtual IBANs” (vIBANs) in EU law. What many PSPs sell as vIBANs are IBAN-formatted identifiers that route to a separate “master account”. This architecture creates reconciliation benefits for merchants, but also a long list of AML/CFT, prudential, and
