Banking Access for FinTechs: Why the US Is More Competitive but Less Predictable, and the UK/EU Is More Orderly but More Limited

25 Nov

How AnyAccount Helps

At AnyAccount, our US team supports FinTech founders, MSBs and scaling payment companies with:

State and federal regulatory licensing strategy, including MSB and money-transmitter frameworks
Bank sponsorship readiness and partner-bank compliance alignment
Technology market launches, including payments infrastructure and AML/KYC controls
End-to-end MSB governance frameworks with operational playbooks and audit trails
Examination preparation across FinCEN, state regulators and sponsor-bank reviews

Our UK/EU specialists support firms navigating FCA and EU requirements, including safeguarding, API authorisation, operational resilience, governance and regulatory filings. If you want to expand across either market without losing weeks to regulatory archaeology, speak to us. We help firms secure compliant, durable banking access in both systems.

Access to banking is the single biggest structural challenge for FinTechs. Whether you are an MSB in the United States or an API in the UK/EU, the ability to open settlement accounts, manage safeguarded funds or run payment flows often determines whether you launch on time — or at all.

But the two major financial blocs operate with fundamentally different regulatory philosophies. The US is diffuse, competitive and market-driven. The UK/EU is orderly, centralised and rules-driven. Each model creates very different environments for FinTechs trying to secure banking partners.

Here are the structural differences that matter most.

1. The US Has Hundreds of Potential Banking Partners — But No Predictability

US financial regulation is fragmented across:

federal regulators
state regulators
sponsor banks
card networks
and, depending on the product, the CFPB and OCC

The upside is that the US has an enormous number of financial institutions. Regional banks, community banks, mid-tier nationals, payments-friendly institutions and specialist FinTech banks all compete for programme-sponsor relationships.

For MSBs and payments companies, this means there is always another bank to talk to. Choice drives competition, and competition drives innovation. The market rewards good controls, good governance and a strong risk-management story.

But the flip side is uncertainty. Every bank has its own risk appetite, its own exam history and its own interpretation of regulatory pressure. As a result, two identical MSBs can receive opposite answers from two different banks in the same week. The system creates optionality, but not predictability.

2. The UK/EU Market Is Narrower — But Far More Consistent

The UK and EU operate under tightly structured rulebooks:

FCA Handbook
PRA Rulebook
PSD2/PSRs
EMD2
and harmonised conduct expectations

Banks operate in a system where regulatory certainty is high and supervisory expectations are centralised. As a result, decisions are far more predictable. If an API has a complete safeguarding model, a credible operational-resilience framework and a compliant onboarding process, UK/EU banks know exactly how to evaluate it.

But the downside is that the market is narrow. The number of banks willing to provide safeguarding accounts, settlement banking or API-level services is limited. Competition is constrained. If the small pool of UK banks becomes risk-averse — as has happened in waves since 2014 & again in 2018 — APIs may find themselves with few alternatives.

In short: the UK/EU offers clarity, but not capacity.

3. US Sponsor Banks Are Commercial Gatekeepers — UK/EU Banks Are Regulatory Gatekeepers

In the US, sponsor banks are effectively compliance partners. They:

review onboarding flows
approve monitoring rules
inspect vendors
analyse governance
test controls
audit MSBs as if they were internal departments

Banks act as extensions of the regulator because they carry the regulatory liability. This creates a high bar, but it also means banks are willing to work creatively with firms that demonstrate robust oversight.

In the UK/EU, the regulator is the primary gatekeeper. Banks can decline applicants — and often do — but their decisions are framed by FCA/ECB expectations. There is less room for commercial flexibility because the regulatory perimeter is very clearly defined.

4. The US Rewards Operational Sophistication — The UK/EU Rewards Compliance Structure

US banks look for evidence. They want to see:

audit logs
testing schedules
real-time dashboards
fraud metrics
escalation trails
incident playbooks

A strong operational spine can persuade even cautious sponsor banks.

UK/EU banks look first for structure:

documented systems
written policies
governance maps
safeguarding procedures
board oversight
formal risk assessments

Both approaches are legitimate. They simply reflect different regulatory architectures.

5. For Banking Access, the US Offers Scale — the UK/EU Offers Stability

The US is a market where MSBs can move fast once they secure a partner. Competition creates opportunities, and the sheer number of banks means FinTechs can shop around until they find the right cultural and risk-fit.

The UK/EU is slower and less flexible, but once a relationship is secured, it tends to be more stable. Regulatory certainty makes banking partnerships predictable and less sensitive to shifts in supervisory tone.

For firms deciding where to launch, the question is simple:
Do you want a large number of potential partners, or a smaller number of highly predictable ones?

Conclusion: Two Systems, Two Philosophies

For MSBs entering the US, success depends on navigating complexity and building operational credibility.
For APIs operating in the UK/EU, success depends on demonstrating disciplined compliance structures within a narrow banking market.

Neither system is easier. They are simply built differently — and FinTechs that understand those differences early will secure banking access faster, with fewer surprises, and with far more control over their expansion trajectory.

Gordon Spencer