Helping the Unbanked Discussion - Should Banking become a Human Right?

When did you send it & how do you know they ignored it?

I had a response saying they wouldn’t share any internal contact details for me to reach out with my proposal

Starling replied on Twitter asking for my email address. Within 15 minutes I had an email from their Chief Commercial Risk Officer asking if I was free to chat.

So… that’s that and also even @TheoGibson couldn’t give me any details either when I asked him

At some point, you’re going to end up in a situation where no financial institutions don’t want your business because either:

  • You’re exposing them to the risk of financial crime or:
  • You’re a risk to their business

I broadly agree that people should have the right to a basic bank account is most circumstances. I think some of the steps financial institutions take are draconian (for example, giving somebody 16 a CIFAS marker for doing something they didn’t know was wrong, especially given our poor financial education in this country).

However I also work in financial crime. I see the scale of things people do, knowingly and are fully complicit in.

This can range from all sorts, from an attempt to defraud the bank themselves, using the bank as a conduit for laundering illegally obtained funds as well as labour and sexual exploitation. In most of those cases keeping the account open would leave the bank open to prosecution, so why should a bank keep that account open?

If that customer then goes to another bank to open an account and they’ve received intelligence that on previous occasions the person has laundered money, or been involved in sexual exploitation - should they be allowed to open another account knowing they’ll likely do the same thing. Is that okay? What about the people who are being scammed/exploited further down the chain?


So this is where my proposal comes in. People who unfortunately have made these decisions should have a “Bank of Last Resort” account opened.

The idea of the BOLR is that the regulatory body is asked to appoint a “criminal customer” a BOLR account by the bank that wants to offload a customer which will be hosted by another bank (example NatWest) or It’s up to the government to choose who hosts this special type of account. Or a new provider could be set up.

This special type of account can be limited so:

It has no debit card
The account holder can only:

Withdraw Cash (ATM or Branch Only)
Pay Direct Debits
Receive their income/salary

This way they still have access to very strict banking. It gives people the access that they need strictly to live

Who is making that decision though, that they’ve done these things? What jury has seen all the evidence of that, what chance have they been given to prove a defence.

I know that people who work in banks think they can tell who is guilty and who isn’t but that just isn’t due process. Neither is information from the police / NCA.

  • How do you withdraw cash without a bank card?
  • How do you pay for the many services which now require a card payment?
  • How do you avoid making it obvious that somebody is banking with a “bank of last resort”
  • Do you give them access to online banking?
  • Do you allow them to use open banking services?
  • What happens if they do something illegal and/or break the terms and conditions of the service?
  • Who pays for this?

It’s not that your idea doesn’t have some merits, but that the practicalities of it are near impossible.


And…. Again. No data to show convictions based on bank flags. Also I mean “we closed your account but we can’t tell you why” says it all on most cases.

I think Blomfield was wrong with the figure of false flags. I think it’s higher

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It can be quite easy to tell when some of these things are going on, there are some very clear indicators which demonstrate it.

We do also get intelligence from the police, NCA etc which help us identify it.

1 - ATM Card
2 - You don’t get that liberty. You only get to pay your bills until your CIFA goes
3 - You don’t. You deserve to look like a tit
4 - No, nothing can be done by the end user. They have no trust
5 - No
6 - They can only get cash out and receive their wage. So I would imagine it’s impossible to screw that up
7 - It something the banks should bang there heads together. It would save more losses in the long run

In a lot of cases there is no wage - the funds moving through the accounts is solely the proceeds of crime. It’s illegal money.

@Dan5 I get banks have to protect themselves and in your experience I am not undermining that you have witnessed horrific actions carried out by people and I’m not in any way saying that what people are doing to innocent people is ok

What I am saying is that at some point there has to be access for these people to access very basic banking facilities. Even if it’s police controlled or government controlled.

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Make it so only approved companies can pay into the special account :man_shrugging:

My idea was an idea from someone with no banking experience. With technology how it is today I’m sure there’s a way to make a stripped back facility that can be monitored

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I find it incredibly worrying you think it is ‘easy’ to decide who is and isn’t guilty of financial crime. That just shows how little you understand of the evidential requirements and understanding of the law that’s required to make such judgements.

They haven’t even been allowed any sort of defence! Deciding someone is guilty of a crime requires lawyers, trials, a judge and an independent jury.

I don’t think the courts are the right analogy here.

Replace ‘bank’ with ‘police’. Do you find it incredibly worrying that police get to decide if the evidence points to someone committing a crime? Is it worrying that they can arrest people and bang them up in jail when they haven’t been found guilty yet?

With the law as it is, regrettably banks have very little discretion. If they think suspicious activity is happening and they don’t report it or block the customer, then they too could be guilty of a crime! It leaves them with no option but to err on the side of caution.

It’s not the banks who are guilty there, ultimately it’s the government because they’ve made the law as it is.

As Les McQueen said, it’s a shit business.


Courts isn’t an ‘analogy’, it is only suitable process to decide if someone is guilty of a crime or not.

The police cannot put people in jail. They can detain them in custody for a limited amount of time but those powers are strictly limited, for good reason. In these circumstances you are entitled to legal representation. It’s the CPS that decides whether to press charges, not the police. So no, I don’t have a problem with this by and large, but I sure would have a problem if the police alone were able to decide on someone’s guilt.

With the law as it is, regrettably banks have very little discretion. If they think suspicious activity is happening and they don’t report it or block the customer, then they too could be guilty of a crime! It leaves them with no option but to err on the side of caution.

This part I get, completely. I’m not saying in any way that individual banks are not making the right decisions under their legal obligations etc. What I am saying, in the post above, there is a vast difference between a bank deciding someone is a ‘risk’, and that person actually being provably guilty of financial crime. When talking about whether someone should or shouldn’t be potentially left unbanked - something I see as the deprivation of a basic right - I think that’s a very important distinction.

I completely agree it’s the system and not the individual banks though.


Well for starters I qualified that it can be quite easy, which isn’t to say that I’m deciding who is and isn’t guilty of financial crime. Neither is Monzo bank making that decision.

We’re looking for indicators of things that suggest a financial crime is occurring on an account. We are often provided with some of those indicators, along with intelligence, from external agencies. There a whole manner of things that we use when making our decisions that, prior to working in financial crime, I just hadn’t thought about being something that were even obvious in the banking system, let alone investigated.

If we think enough of those indicators exist then, as all financial institutions are obliged to, we submit a SAR to the NCA. It’s then up to them to act and push it through the court system, they decide whose guilty not us. We don’t inform other banks that we’ve closed a customers account, but the NCA might do so.

We are judge and jury, but we are obliged to operate within the law - whether or not you agree with that law is a different argument.


Neither can a bank they can freeze funds temporarily, but they can only withhold them for longer if the NCA applies for a court order. The decision rests with them, not the bank.


My argument is less of that and more along the lines of is it possible to provide these people who may or may not have committed or in the process of committing financial crime with very stripped bank banking services that could be monitored by an external agency for example like the NCA or Police?

Who would fund that? The police are already stretched. To ensure round the clock monitoring of tens of thousands of fraudulent accounts would be an enormous drain on taxpayers

They don’t have the resources to do their existing workload, let alone add more to it.

Like I said - the complexities here are massive and whilst I admire the idea there are other solutions out there. Including basic bank accounts and credit unions. For most people they will suffice. For those that it doesn’t work for, most of them get their money paid into somebody else’s account.