INDEX / DIRECTORY / STARLING BANK / ECONOMIC

Starling Bank ECONOMIC

ECONOMIC AUDIT UPDATED 2026-09-22
Economic Score 0.00 /10 E Starling Bank - BDS-1000 0
Economic 0.00

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Supply Chain & Sourcing Relationships

Starling operates as a UK banking, lending, payment-services and software-services group, rather than as a retail-goods seller or importer. Its FY2024 country-by-country disclosure describes a UK deposit-taking and lending business developing SaaS products, with only immaterial amounts attributed to a non-operating Irish subsidiary.1

No public evidence identified of direct Israeli supplier relationships, importer-of-record activity, Israeli-goods procurement, reseller or white-label sourcing arrangements, settlement-origin product sourcing, or DEFRA/customs enforcement concerning Starling in the reviewed disclosures and targeted searches.1, 2, 3, 4

No public evidence identified of a Starling corporate sourcing or country-of-origin-labelling policy concerning Israeli or occupied-territory goods; this is consistent with, but not established by, Starling’s non-retail business model.1, 3, 5

The FY2025 consolidated group included mortgage, software-services and holding-company entities registered or operating in England, Wales and Ireland.6 Fleet Mortgages Limited, acquired in full in July 2021 for consideration valued at £50.171 million, originates, sells and services buy-to-let mortgages principally for professional and semi-professional landlords.6

Starling announced an agreement to acquire London-based accounting and tax-platform provider Ember on 19 August 2025, describing it as its first acquisition since Fleet.7 Companies House records Ember by Starling Limited as an active English company under Starling Bank’s control from 28 August 2025, but does not disclose a purchase price, precise ownership percentage, or whether the acquisition was 100%.8, 9

No Israeli operating subsidiary, Israeli acquisition, Israeli-controlled operating company, or Israeli manufacturing location was identified in the FY2025 subsidiary list or the reviewed Ember records.6, 7, 8

Product Origin, Labeling & Regulatory Compliance

Starling is incorporated under SIC 64191 (“Banks”) and is not presented in the reviewed records as a seller of physical consumer products requiring origin labels.2

No public evidence identified of settlement-origin products, origin-labelling practices, customs action, DEFRA action, or Starling policies specifically governing Israeli-origin goods.2, 3

Starling states that it is authorised by the Prudential Regulation Authority and regulated by the Financial Conduct Authority and Prudential Regulation Authority under reference number 730166.10, 11 Its legal terms identify Starling Bank Limited as an England-and-Wales registered company subject to PRA and FCA regulation.12

As at 22 September 2026, Starling’s help page listed both “Gaza Strip (State of Palestine)” and “West Bank (State of Palestine)” among territories from which it could not accept payments, while stating that the list could change.3 This is a payment-acceptance restriction, not evidence of operations in either territory, a settlement-specific policy, or a restriction on every outbound or card transaction.3

Starling’s public international-transfer offer states that customers can send money to 34 countries in 17 currencies, and its published destination-and-fee table does not list Israel.4, 13 Those pages do not establish whether exceptional SWIFT transfers to Israeli institutions in another supported currency are possible, so the omission cannot establish that every Israel-directed transfer is unavailable.4, 13

Starling’s May 2026 personal-account terms state that other companies and banks may participate in processing international payments.14 Its January 2026 euro-account terms state that Starling uses an intermediary bank for international payments and that recipient banks may use intermediaries.15 Neither document identifies an Israeli correspondent, Israeli bank, settlement enterprise, defence-sector counterparty, or local payment provider.14, 15

Starling describes Banking Services as providing access to UK Faster Payments and Bacs, with Starling a direct participant in those UK schemes.5, 16 The reviewed materials identify no Israeli payment-rail access, Engine client, API client, or Starling service contract in Israel or the occupied territories.5, 16

Investment, Capital & Financial Exposure

For the year ended 31 March 2024, Starling reported group revenue of £682.2 million and profit before tax of £301.1 million.1 Starling subsequently described FY2026 as its fifth consecutive year of profitability, although the reviewed current release does not alter the FY2024 figures above.11

The FY2024 and FY2025 disclosures did not identify Israel-attributed revenue, Israeli operating investment, Israeli portfolio holdings, or Israeli assets.1, 6

No public evidence identified of Starling underwriting or arranging Israeli sovereign debt, Israel Bonds or war bonds; lending or trade-finance facilities for Israeli defence primes or OHCHR-listed enterprises; insurance underwriting; Israeli portfolio holdings; or Israel-focused funds in the reviewed public materials.1, 6, 10, 17, 18

The 15 June 2026 Admission Particulars report £6.8 billion in group debt securities at 31 March 2026, comprising UK gilts and T-bills, sub-sovereign, supranational and agency bonds, residential mortgage-backed securities, and covered bonds.18 The disclosure does not identify individual issuers, countries, Israel Bonds, Israeli sovereign debt, Israeli corporates, settlement-active enterprises, or Israeli defence companies, and therefore cannot confirm or exclude all such exposure.18

A 2022 Bank of Israel payments conference included Starling’s Sam Everington discussing the UK neobank’s experience, but the official release does not document an investment, contract, licence, deployment, customer relationship, or Israeli operation by Starling.17

The reviewed public materials do not provide loan-book, counterparty, securities-portfolio, correspondent-banking, merchant-flow, or recipient-level detail sufficient to independently exclude every possible Israeli corporate, sovereign, settlement-linked, defence-linked, customer, payment, or securities exposure.1, 18, 14, 15

No public evidence identified in the retrieved person-specific searches of a personal or family-office investment by JTC Starling Holdings, McPike family-office vehicles, Anne Boden, Harald McPike-Zima, or the current Starling directors in an Israeli company, Israel-focused fund, Israeli sovereign debt, Israeli defence company, or OHCHR-listed settlement enterprise.18, 19, 20 This is a limited public-evidence finding rather than a complete portfolio-absence conclusion, because the McPike portfolio is expressly a selection and the reviewed sources do not provide complete investment, trust, foundation, or beneficial-ownership records.19, 20

No qualifying Israeli-economy exposure was established in the reviewed evidence; accordingly, no public value, ownership percentage, duration, beneficiary, or present status for such an exposure is documented.18, 19, 20

Operational Presence & Market Activity

Starling Bank Limited is an active English private company limited by shares, incorporated on 18 June 2014, with its registered office at 5th Floor, London Fruit and Wool Exchange, 1 Duval Square, London E1 6PW.2 Its former names were Possible FS Limited from 18 June 2014 to 5 January 2016 and Starling FS Limited from 5 January to 15 July 2016.2

Companies House records FY2026 group accounts as filed on 12 July 2026, with accounts made up to 31 March 2026 and the latest confirmation statement dated 17 February 2026.2, 21 The register also records 2025 restructuring filings, including adoption of articles and variation of share rights on 8 July 2025.21

Starling’s FY2024 annual report states that its customer-service agents are UK-based.1 Its personal-account application page requires applicants to live in the UK and describes GBP, euro and US-dollar account products.22

The FY2025 subsidiary disclosure identifies group registrations and operating addresses in England, Wales and Ireland, without an Israeli subsidiary or operating address.6 Starling’s FY2026 annual-report page identifies offices newly opened in New York, Toronto and Dubai alongside a new London headquarters, while its accompanying release describes 12 global offices and home-market locations in Southampton, Cardiff, Manchester and Fleet.23, 11

No public evidence identified of Starling offices, branches, support centres, warehouses, retail sites, local workforce, tax registration, R&D facility, accelerator programme, or sales operations in Israel, the West Bank including East Jerusalem, or the Golan Heights.6, 23, 11

No public evidence identified of Starling services, sales, sourcing, listings, distribution, revenue, contracts, branches, customers, or counterparties located in Israeli settlements in the West Bank including East Jerusalem or in the Golan Heights.24, 25, 26, 3

The West Bank and Gaza payment-acceptance restriction is post-July and post-November 2024 evidence, but it is not a qualifying Israeli-state, settlement, or occupied-territory commercial activity; no post-threshold continuation of such activity was identified in the reviewed sources.3

Corporate Structure & Foundational Ties

Starling Intermediate Holdings Limited holds more than 75% of Starling Bank Limited’s shares and voting rights and has appointment-and-removal rights over its directors; Companies House records it as direct PSC from 30 September 2025.27, 28, 21 Starling Intermediate Holdings Limited is an active English financial-services holding company, incorporated on 10 February 2025 and registered at Starling’s London address.29

Starling Group Holdings Limited holds more than 75% of Starling Intermediate Holdings Limited’s shares and voting rights and has corresponding director appointment-and-removal rights.28, 30 It is an active English financial-services holding company, incorporated on 25 January 2022 at the same address.30

Harald McPike-Zima is the sole active PSC disclosed for Starling Group Holdings Limited, holding more than 25% but no more than 50% of shares and voting rights, including control over trustees of a trust.30 Companies House does not disclose his precise percentage or the trust’s beneficial owners.30

The June 2026 Admission Particulars identify JTC Starling Holdings Limited, part of McPike Global Family Office, as holding 37.5% of the relevant issuer’s shares and 40.9% of voting rights; they identify Harald McPike-Zima as the family office’s founder and state that no other person or entity held more than 25% of the issuer’s shares.18 The document identifies Chrysalis, Fidelity Management & Research, Railpen, Qatar Investment Authority, Millennium Management, Goldman Sachs, Anne Boden, directors, employees and employee-benefit trusts as other shareholders.18

The same document states that JTC appointed an investor non-executive director under the articles and shareholder agreement and that the issuer and Starling Bank have mirror boards.18 These facts establish shareholder governance and representation links between JTC/McPike and Starling, but do not establish shared management, common investment committees, intercompany service agreements, Starling-directed mandates, operational integration, or concerted activity between Starling and other McPike portfolio companies.18, 19, 20

McPike Family Office describes itself as a Bahamas-based office deploying capital through a direct-equity vehicle and QuantRes Asset Management, a systematic liquid-markets vehicle, and lists Starling among a selection of current portfolio companies.19, 20 Its statement that the full portfolio is available only on request prevents the public selection from establishing a complete portfolio absence conclusion.20

Raman Bhatia is Starling’s Group CEO and Declan Ferguson its Group CFO.31 Current Companies House records list Colin Bell, Raman Bhatia, Julie Chakraverty, Declan Ferguson, John Mountain, Daniel Olley and Darren Pope as active directors, including appointments of Bell on 6 October 2025, Mountain on 18 June 2026, and Olley on 1 July 2026.32 Starling’s board page identifies the same current board membership.33

Colin Bell’s disclosed career history includes British Army service and roles with the UK Ministry of Defence and NATO, but this is not evidence of an Israel, settlement, political-contribution, or arms-industry relationship.33, 34 Anne Boden founded Starling, served as a director from incorporation until 30 June 2024, and joined the UK Government’s Board of Trade as an adviser in October 2020.32, 35

No public evidence identified that Starling was founded in Israel, is Israel-headquartered, maintains principal management or tax residency in Israel, holds Israeli Preferred Technology Enterprise status, is controlled by Israeli capital, is Israeli state-owned, has Israeli government appointees, holds an Israeli critical-infrastructure designation, or has Israeli-state-linked governance mechanisms.2, 6, 10

The reviewed document corpus recorded no Starling Bank mention in the cited UN Special Rapporteur report or the 2023 and 2025 OHCHR settlement-business database updates; this is document-scoped and does not establish database-wide or real-world absence.24, 25, 26

Profit Repatriation & Economic Contribution

No public evidence identified of Israel-attributed revenue, profits repatriated to Israel, Israeli-domiciled ownership receiving Starling profits, or an assessment characterising Starling as an Israeli economic-sector employer or infrastructure provider.1, 2, 17

Starling’s FY2025 report states that its direct and indirect subsidiaries were fully consolidated, including entities in England, Wales and Ireland.6 The FY2026 corporate materials describe a growing international office footprint, but identify no Israeli office or Israeli operating location.23, 11

Starling’s 2017 annual report stated that the group made no political donations in that period and reported £1,500 in charitable donations to MyBnk.36 Starling’s 2018 annual report likewise stated that the group made no political donations and reported £2,610 in charitable donations to MyBnk and Cancer Research UK.37

The reviewed materials do not support a conclusion about political donations, lobbying, personal investments, Israel- or Palestine-related statements, or charitable activity by every current director, former founder, investor, or associated family-office vehicle.18, 32, 33, 19, 20 Examiner-directed cross-domain principal research identified a U.S. private foundation bearing the McPike-Zima name: its 2015 Form 990-PF identifies Harald McPike as an $11 million substantial contributor, and the latest located IRS-recorded return reports $1.605 million of 2024 charitable disbursements and $56.117 million in net assets.38, 39 The accessible 2023 and 2024 return presentation did not render a complete itemised grant schedule, so the reviewed record supports neither an Israel/Palestine-linked recipient finding nor a comprehensive recipient-level absence conclusion.38

Footnotes

  1. https://www.starlingbank.com/docs/annual-reports/Starling-Bank-Annual-Report-2024.pdf ↩ ↩2 ↩3 ↩4 ↩5 ↩6 ↩7 ↩8 ↩9

  2. https://find-and-update.company-information.service.gov.uk/company/09092149 ↩ ↩2 ↩3 ↩4 ↩5 ↩6 ↩7 ↩8

  3. https://help.starlingbank.com/business/topics/sending-and-receiving-money/are-there-any-countries-which-starling-doesnt-allow-payments-to-or-from/ ↩ ↩2 ↩3 ↩4 ↩5 ↩6 ↩7

  4. https://www.starlingbank.com/send-money-abroad/ ↩ ↩2 ↩3

  5. https://www.starlingbank.com/banking-services/ ↩ ↩2 ↩3

  6. https://www.starlingbank.com/docs/annual-reports/Starling-Bank-Annual-Report-2025.pdf ↩ ↩2 ↩3 ↩4 ↩5 ↩6 ↩7 ↩8 ↩9

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

  8. https://find-and-update.company-information.service.gov.uk/company/11822163 ↩ ↩2

  9. https://find-and-update.company-information.service.gov.uk/company/11822163/persons-with-significant-control ↩

  10. https://www.starlingbank.com/about/ ↩ ↩2 ↩3

  11. https://www.starlingbank.com/news/starling-delivers-fifth-year-of-profitability-and-accelerates-global-growth-strategy/ ↩ ↩2 ↩3 ↩4 ↩5

  12. https://www.starlingbank.com/legal/terms-of-use/ ↩

  13. https://www.starlingbank.com/send-money-abroad/country-fees/ ↩ ↩2

  14. https://www.starlingbank.com/docs/legal/terms/starling-personal-account-general-terms-may-2026.pdf ↩ ↩2 ↩3

  15. https://www.starlingbank.com/docs/legal/terms/starling-personal-euro-current-account-terms-jan-2026.pdf ↩ ↩2 ↩3

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

  17. https://www.boi.org.il/en/communication-and-publications/press-releases/the-bank-of-israel-holds-a-conference-on-a-look-at-the-future-world-of-payments/ ↩ ↩2 ↩3

  18. https://www.rns-pdf.londonstockexchange.com/rns/3664I_1-2026-6-15.pdf ↩ ↩2 ↩3 ↩4 ↩5 ↩6 ↩7 ↩8 ↩9 ↩10 ↩11

  19. https://www.mcpikeventures.com/index.html ↩ ↩2 ↩3 ↩4 ↩5 ↩6

  20. https://www.mcpikeventures.com/portfolio.html ↩ ↩2 ↩3 ↩4 ↩5 ↩6 ↩7

  21. https://find-and-update.company-information.service.gov.uk/company/09092149/filing-history?page=1 ↩ ↩2 ↩3

  22. https://www.starlingbank.com/open-bank-account-online/ ↩

  23. https://www.starlingbank.com/investors/2026/annual-report-2026/ ↩ ↩2 ↩3

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

  25. https://docs.un.org/en/A/HRC/52/76 ↩ ↩2

  26. https://docs.un.org/en/A/HRC/60/19 ↩ ↩2

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

  28. https://find-and-update.company-information.service.gov.uk/company/16240204/persons-with-significant-control ↩ ↩2

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

  30. https://find-and-update.company-information.service.gov.uk/company/13871603/persons-with-significant-control ↩ ↩2 ↩3 ↩4

  31. https://www.starlingbank.com/docs/annual-reports/Pillar3-2025.pdf ↩

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

  33. https://www.starlingbank.com/about/board-of-directors/ ↩ ↩2 ↩3

  34. https://www.man.com/colin-bell?team=man-group-board ↩

  35. https://www.gov.uk/government/news/new-board-of-trade-holds-first-meeting-featuring-welsh-tech-entrepreneur-anne-boden ↩

  36. https://www.starlingbank.com/docs/annual-reports/Starling-bank-annual-report-2016-17.pdf ↩

  37. https://www.starlingbank.com/docs/annual-reports/Starling-bank-annual-report-2017-18.pdf ↩

  38. https://projects.propublica.org/nonprofits/organizations/812617818 ↩ ↩2

  39. https://990s.foundationcenter.org/990pf_pdf_archive/812/812617818/812617818_201512_990PF.pdf ↩