INDEX / DIRECTORY / STARLING BANK / DIGITAL

Starling Bank DIGITAL

DIGITAL INFRASTRUCTURE AUDIT UPDATED 2026-09-22
Digital Score 0.00 /10 E Starling Bank - BDS-1000 0
Digital 0.00

Evidence-only forensic audit. Scoring happens downstream - see the main dossier for the composite assessment.

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Enterprise Technology Stack & Vendor Relationships

Starling Bank Limited is an active UK private limited company, incorporated on 18 June 2014 and classified under SIC 64191 (banks); its register records former names Possible FS Limited and Starling FS Limited.1 Starling’s FY2025 reporting describes the group as comprising Starling Bank, Engine by Starling and Fleet Mortgages.2

Starling states that its core banking and payment platform is cloud-based, uses proprietary software for payment-scheme connections, and is managed and built by Starling.3 Starling FS Services Limited is an active, wholly owned group subsidiary responsible for software design, specification, build, testing and implementation supporting the mobile-banking platform; it is classified as an information-technology services company.4, 5, 6

Current engineering recruitment material identifies AWS among technologies used by Starling engineering teams.7 AWS documented that Starling was built on AWS in 2017, while a 2019 AWS Marketplace case study quoted Starling’s Director of Technology as saying that “the bank runs in AWS”; these are historical statements rather than independent confirmation of every current workload.8, 9

Starling’s AI notice identifies Google Cloud Platform and AWS as providers of certain large-language-model and machine-learning models used in Starling AI tools.10 Google Cloud states that Starling uses BigQuery, Vertex AI, Gemini, Model Armor, Vertex AI Workbench and Vertex AI Pipelines for data-warehouse, AI-development, customer-facing and internal functions.11

No public evidence identified of a disclosed licensing, subscription, integration, managed-service, systems-integrator, or outsourcing relationship through which Starling uses specifically identified Israeli-origin enterprise or cybersecurity technology.10, 7

Surveillance, Biometrics & Retail Technology

Starling discloses AI uses for fraud prevention, account-application review, customer-service support, Scam Intelligence and Spending Intelligence.10 Google Cloud describes related uses including customer-service call-transcript summarisation, help-centre responses, Scam Intelligence and Spending Intelligence.11

The disclosed external AI-model providers are Google Cloud Platform and AWS.10 no public evidence identified of Starling’s use of Israeli-origin facial recognition, biometric identification, gait analysis, retail analytics, predictive policing, social-media monitoring, sentiment analysis, or workforce-surveillance products.10, 7

No public evidence identified that biometric or surveillance technology reaches Starling indirectly through a managed-security provider or bundled platform.10, 7

Cloud Infrastructure, Data Residency & Sovereign Cloud Participation

Starling’s privacy notice states that it stores and processes information, where possible, on servers in the UK and EEA, while transfers outside those locations may occur where a supplier processes data elsewhere or in connection with international payments or messages.12 The notice does not identify Israel as a storage, processing or transfer location.12

Starling states that processing for its relevant Google Cloud Platform and AWS AI-model uses is managed and stored by Starling in the EEA.10 Starling further states that external AI companies do not retain access to Starling data or train their models on that data.10

No public evidence identified that Starling operates, leases or colocates a data centre in Israel, or that a disclosed customer-data pipeline is routed through Israeli infrastructure or subject to Israeli jurisdiction.10, 12, 13 no public evidence identified of Starling participation in Project Nimbus or another Israeli-government cloud programme.10, 11, 3

Starling’s public disclosures do not identify all cloud regions, sub-processors, security tools, telemetry routes, data-replication arrangements, AWS regions, contract values, workload volumes or the complete scope of supplier access.10, 11, 12, 8, 9

Defence, Intelligence & Security Sector Technology Relationships

No public evidence identified of a Starling contract, partnership or service agreement with the Israeli Ministry of Defence, IDF, Israeli intelligence agencies or another Israeli security body.13, 14 no public evidence identified that Starling’s banking, payment, API, cloud or AI products have been documented as deployed by Israeli military, intelligence or law-enforcement bodies in Israel or the occupied Palestinian territory.10, 3

No public evidence identified that Starling develops, sells, licenses or maintains offensive cyber tools, zero-day exploits or digital-weapons systems.10, 13 no public evidence identified that Starling markets or contracts digital-sovereignty, data-residency or resilience services to Israeli state institutions or military bodies.3, 14

Starling’s business-customer help page lists “West Bank (State of Palestine)” among jurisdictions to or from which it does not allow payments.15 The retrieved page does not identify an Israeli state, settlement, defence, intelligence or technology counterparty, or explain the operational basis for that restriction.15

AI, Algorithmic & Autonomous Systems

Starling’s disclosed AI functions concern banking activities including fraud detection, account-application review, customer support, Scam Intelligence, Spending Intelligence and financial-information queries.10, 11 Google Cloud identifies BigQuery for the data warehouse and Vertex AI services for model development and operational AI functions.11

No public evidence identified that Starling provides AI/ML, computer-vision, autonomous decision-support or related systems to Israeli state, military, intelligence or security bodies.10, 11 no public evidence identified that Starling models have been trained on Israeli or occupied-territory civilian data, intercepted communications or surveillance-derived datasets.10

No public evidence identified of Starling provision of autonomous target-generation, kinetic-targeting, automated-tracking or other weapons-directed systems.10, 13

Technology Ecosystem & R&D Footprint

Starling’s current group disclosure identifies Starling Bank and Engine by Starling as principal operating subsidiaries; it identifies Fleet Mortgages as a Starling Bank subsidiary and Engine as a wholly owned indirect Starling Group Holdings subsidiary.16 Starling FS Services Limited and Murmur Financial Services Limited remained SIHL subsidiaries potentially subject to reorganisation during 2026.16

Engine by Starling Limited is active and classified as an information-technology services company.17, 18 Fleet Mortgages Limited is active, and Starling Bank Limited has held at least 75% of its shares and voting rights since 23 July 2021.19

Starling announced a proposed acquisition of London-based accounting and tax platform Ember in August 2025, subject to customary closing conditions.20 Its May 2026 results state that the Group acquired Ember, and the June 2026 Admission Particulars identify Ember by Starling Limited among Group directorships held by Declan Ferguson.21, 16 No reviewed source identifies Ember as Israeli-domiciled or as having Israel or occupied-territory operations.16, 20, 21

Starling’s May 2026 disclosure describes the Group as headquartered in London with 12 offices worldwide, including Southampton, Cardiff, Manchester and Fleet.21 Its 2026 annual-report page identifies Engine offices in New York, Toronto, Dubai and London.22, 23 Earlier published material identified Cardiff, London, Manchester, Southampton and Dublin.5 None of these corporate disclosures identifies an office, legal entity or operating location in Israel or the occupied Palestinian territory.5, 22, 21

No public evidence identified of a Starling R&D centre, engineering office, innovation lab or accelerator programme in Israel.2, 14 no public evidence identified of Starling acquiring an Israeli technology company, making a strategic investment in an Israeli technology startup or venture fund, or entering significant patent, licensing or co-development arrangements with Israeli-domiciled entities.13, 14, 24

Starling Bank Limited’s direct PSC is Starling Intermediate Holdings Limited, holding more than 75% of shares and voting rights and the right to appoint or remove directors.25 SIHL is an active English financial-services holding company incorporated on 10 February 2025, and its sole active PSC is Starling Group Holdings Limited, with equivalent control rights.26, 27

The June 2026 Admission Particulars state that Starling Group Holdings became the Group’s non-operating bank holding company on 27 June 2025 and is Starling Bank’s indirect sole shareholder through wholly owned SIHL.16 At that date, JTC Starling Holdings Limited, part of McPike Global Family Office, held 37.5% of Starling Group Holdings shares and 40.9% of voting rights; no other person or entity held more than 25% of shares or voting rights, and Anne Boden was identified among shareholders without a stated stake.16 Companies House records Harald McPike-Zima as Starling Group Holdings’ PSC, with more than 25% but not more than 50% ownership and voting rights and control over trustees of a trust.28

No public evidence identified in focused public-record research of equity, board, or controlling interests in Israeli defence-tech, surveillance, cyber, cloud, data, or military-technology companies held by Harald McPike-Zima or McPike Global Family Office.29 The publicly displayed McPike portfolio is expressly a selection rather than a complete register and lists Starling, Tembo, Acre, Health Data Analytics Institute and Imagr.ai; it therefore cannot establish absence of undisclosed holdings.29

Anne Boden’s site identifies AI by Boden Ltd and BodenOffice.com as her platform and family office.30 AI by Boden Ltd is active in England and registered for financial-management and management-consultancy activities.31 no public evidence identified in focused public-record research of an Israeli technology-company investment, controlling interest or board role held by Boden, Boden Office or AI by Boden Ltd; neither reviewed source provides a complete investment register.30, 31

Current Companies House records list Colin Bell, Raman Bhatia, Julie Chakraverty, Declan Ferguson, John Mountain, Dan Olley and Darren Pope as Starling Bank directors.32 no public evidence identified in focused public-record research of Israeli defence-tech, surveillance, cyber, cloud, data, or military-technology equity, board, or control interests involving those directors.16, 32 This is a bounded public-record result, not confirmation that private or unreported interests do not exist.16, 32

No investment satisfying those principal-level criteria was identified; accordingly, no verified digital downstream result, Israeli state or security beneficiary, ownership stake, control right, or current or historical status attributable to such an investment was identified.16, 32, 29, 30, 31

Civil Society Scrutiny & Regulatory History

The supplied deterministic full-text pre-scan found no mention of “Starling Bank” in the 2023 OHCHR settlement-business database or the UN Special Rapporteur’s A/HRC/59/23 report.33, 34 These are document-scoped findings and do not establish absence under group-company, former-name, investor or principal names.33, 34

No public evidence identified of NGO, academic, UN, boycott, divestment, sanctions, export-control or litigation material specifically addressing Starling technology provision to Israeli state bodies or operations in occupied territories.10, 13, 24 no public evidence identified of an organised campaign directed at Starling concerning technology provision to Israel or the occupied territories, or of a corresponding documented company response.2, 24

The FCA’s 27 September 2024 Final Notice concerned Starling’s financial-crime systems and controls, including sanctions screening, rather than technology provision to Israeli entities or occupied territories.35, 36 The FCA imposed a £28,959,426 penalty, and its accompanying release states that Starling identified in January 2023 that its automated screening system had screened customers against only a fraction of the full sanctions list since 2017.35, 36

Footnotes

  1. https://find-and-update.company-information.service.gov.uk/company/09092149 ↩

  2. https://www.starlingbank.com/docs/annual-reports/Starling-Bank-Annual-Report-2025.pdf ↩ ↩2 ↩3

  3. https://www.starlingbank.com/banking-services/how-starling-provides-you-with-access-to-real-time-payments/ ↩ ↩2 ↩3 ↩4

  4. https://find-and-update.company-information.service.gov.uk/company/10091094 ↩

  5. https://www.starlingbank.com/legal/modern-slavery-statement/ ↩ ↩2 ↩3

  6. https://find-and-update.company-information.service.gov.uk/company/10091094 ↩

  7. https://www.starlingbank.com/careers/engineering/ ↩ ↩2 ↩3 ↩4

  8. https://aws.amazon.com/blogs/startups/reinventing-the-banking-model/ ↩ ↩2

  9. https://aws.amazon.com/blogs/awsmarketplace/starling-bank-releases-android-apps-faster-with-genymotion-from-aws-marketplace/ ↩ ↩2

  10. https://www.starlingbank.com/legal/privacy-notice/ai-privacy/ ↩ ↩2 ↩3 ↩4 ↩5 ↩6 ↩7 ↩8 ↩9 ↩10 ↩11 ↩12 ↩13 ↩14 ↩15 ↩16 ↩17 ↩18

  11. https://cloud.google.com/customers/starling ↩ ↩2 ↩3 ↩4 ↩5 ↩6 ↩7

  12. https://www.starlingbank.com/legal/privacy-notice/ ↩ ↩2 ↩3 ↩4

  13. https://technology.starlingbank.com/blog/engineering-delivery-part-ii ↩ ↩2 ↩3 ↩4 ↩5 ↩6

  14. https://www.starlingbank.com/media/company-fact-sheet/ ↩ ↩2 ↩3 ↩4

  15. https://help.starlingbank.com/business/topics/sending-and-receiving-money/are-there-any-countries-which-starling-doesnt-allow-payments-to-or-from/ ↩ ↩2

  16. https://www.rns-pdf.londonstockexchange.com/rns/3664I_1-2026-6-15.pdf ↩ ↩2 ↩3 ↩4 ↩5 ↩6 ↩7 ↩8 ↩9

  17. https://find-and-update.company-information.service.gov.uk/company/13925405/filing-history ↩

  18. https://find-and-update.company-information.service.gov.uk/company/13925405 ↩

  19. https://find-and-update.company-information.service.gov.uk/company/08663979/persons-with-significant-control ↩

  20. https://www.starlingbank.com/news/starling-agrees-to-buy-ember/ ↩ ↩2

  21. https://www.starlingbank.com/news/starling-delivers-fifth-year-of-profitability-and-accelerates-global-growth-strategy/ ↩ ↩2 ↩3 ↩4

  22. https://www.starlingbank.com/investors/2026/annual-report-2026/ ↩ ↩2

  23. https://www.starlingbank.com/investors/2026/annual-report-2026/ ↩

  24. https://www.starlingbank.com/investors/2025/annual-report-2025/ ↩ ↩2 ↩3

  25. https://find-and-update.company-information.service.gov.uk/company/09092149/persons-with-significant-control ↩

  26. https://find-and-update.company-information.service.gov.uk/company/16240204 ↩

  27. https://find-and-update.company-information.service.gov.uk/company/16240204/persons-with-significant-control ↩

  28. https://find-and-update.company-information.service.gov.uk/company/13871603/persons-with-significant-control ↩

  29. https://www.mcpikeventures.com/index.html ↩ ↩2 ↩3

  30. https://www.bodenoffice.com/ ↩ ↩2 ↩3

  31. https://find-and-update.company-information.service.gov.uk/company/07655137 ↩ ↩2 ↩3

  32. https://find-and-update.company-information.service.gov.uk/company/09092149/officers ↩ ↩2 ↩3 ↩4

  33. https://www.ohchr.org/sites/default/files/documents/hrbodies/hrcouncil/sessions-regular/session31/database-hrc3136/23-06-30-Update-israeli-settlement-opt-database-hrc3136.pdf ↩ ↩2

  34. https://docs.un.org/en/A/HRC/59/23 ↩ ↩2

  35. https://www.fca.org.uk/publication/final-notices/starling-bank-limited-2024.pdf ↩ ↩2

  36. https://www.fca.org.uk/news/press-releases/fca-fines-starling-bank-failings-financial-crime-systems-and-controls ↩ ↩2