Starling Bank MILITARY

Direct Defence Contracting & Procurement

• Starling Bank Limited is the operating digital bank, authorised by the PRA and regulated by the FCA and PRA; its disclosed group activities include personal and business banking, buy-to-let lending through Fleet Mortgages, and banking-platform software through Engine by Starling.^{1, 2, 3}
• Since 27 June 2025, Starling Group Holdings Limited has been the PRA-approved non-operating financial holding company above Starling Bank Limited, which it indirectly wholly owns through Starling Intermediate Holdings Limited.^{1, 4, 5}
• No public evidence identified of a contract, tender award, framework agreement, memorandum, SIBAT-directory listing, defence-exhibition listing, or official Israeli procurement record linking Starling Bank, Engine, Fleet Mortgages, Starling FS Services, or disclosed holding entities to the Israeli Ministry of Defense, IDF, Israel Prison Service, Border Police, or another Israeli-security body.^{1, 3, 6, 7, 8}
• A 2022 Bank of Israel report records a payments-and-advanced-technologies discussion involving the Bank’s Deputy Supervisor of Banks and Starling’s Sam Everington, but does not document a licence, commercial contract, deployment, procurement award, or Israeli state-security relationship.⁹
• A 2019 Bank of Israel report mentioned Starling as a UK digital-bank example in an international banking-market discussion; it does not document Israeli operations, a Bank of Israel licence, or an Israeli defence relationship.¹⁰
• A search false positive concerns Starling Advanced Communications Ltd., a separate Israeli satellite-communications company in which Elbit reported an equity interest in 2007; that filing does not identify Starling Bank Limited and provides no evidentiary link to the target.¹¹

Dual-Use Products & Tactical Variants

• Starling’s FY2025 disclosures describe Engine as the group vehicle for proprietary banking technology, and identify Salt Bank in Romania and AMP Bank in Australia among disclosed SaaS customers.^{3, 6}
• FY2026 reporting additionally identifies Engine customers Tangerine Bank in Canada and SBS Bank in New Zealand, alongside Salt Bank and AMP Bank Go; the reviewed disclosures do not identify an Israeli Engine customer.^{1, 12, 13}
• Starling FS Services Limited is a wholly owned subsidiary described as designing, building, testing, and implementing software supporting the mobile-banking platform.^{14, 3}
• Engine describes a cloud-native managed core-banking platform for banks, credit unions, and mutuals, with account, ledger, payment/card-processing, lending, workflow, customer-data, AML, fraud, payment-screening, and customer-screening functions.^{15, 16}
• No reviewed source identifies a tactical, ruggedised, defence-grade, military-specific, targeting, fire-control, weapons-integration, or Israeli-security end-use product supplied by Starling or Engine.^{1, 3, 15, 16}
• No public evidence identified of export-licence applications, end-user certificates, or export-control decisions concerning Starling products for Israeli military or security end-users.^{1, 3, 15, 16}

Heavy Machinery, Construction & Infrastructure

• The disclosed group businesses are banking, buy-to-let mortgage origination and servicing, and banking-platform software, rather than equipment manufacturing or construction contracting.^{1, 3}
• No public evidence identified that Starling or its disclosed group companies manufacture, supply, finance, service, or operate heavy machinery; conduct construction or engineering work; or support checkpoints, the separation barrier, military installations, settlements, or demolitions.^{1, 3, 6, 7, 8}
• No reviewed corporate source identifies an Israeli-incorporated Starling subsidiary, Israeli branch, franchisee, licensee, group office, or operation in the West Bank, including East Jerusalem, Gaza, or the Golan Heights.^{1, 12, 13}

Supply Chain Integration with Defence Primes

• No public evidence identified of supply, co-development, licensing, equity, manufacturing, services, or other commercial relationships between Starling group entities and Elbit Systems, Israel Aerospace Industries, Rafael, IMI/Elbit Land, or another Israeli defence prime.^{1, 3, 11}
• The Elbit filing naming Starling Advanced Communications Ltd. concerns a separate Israeli communications entity and cannot establish a relationship with Starling Bank Limited.¹¹
• As of 15 June 2026, JTC Starling Holdings Limited held 37.5% of Starling Group Holdings’ shares and 40.9% of voting rights; JTC is described as part of McPike Global Family Office, which oversees Harald McPike-Zima’s investment activity, while no other person or entity held more than 25% of Starling Group Holdings’ shares or voting rights.¹
• Companies House records Harald McPike-Zima as Starling Group Holdings’ sole active PSC, with more than 25% but no more than 50% of shares and voting rights and control over trustees of a trust.¹⁷
• No public evidence identified in the reviewed ownership disclosures, appointment register, family-office description, targeted searches, and canonical materials that Harald McPike-Zima, JTC Starling Holdings, McPike Global Family Office, Anne Boden, or identified current Starling controlling principals hold controlling or material equity, board roles, or operating interests in entities documented as supplying physical goods, infrastructure, or logistics to Israeli military, prison, police, border, or settlement-security bodies.^{1, 18, 19, 7, 8, 17, 20}
• Anne Boden is named as an SGHL shareholder, but the June 2026 admission particulars do not disclose her holding percentage; she resigned as an SBL director on 30 June 2024 and as an SGHL director on 14 June 2023.^{1, 19}
• A pre-2020 trade-press report describes Harald McPike/Sage Technologies as an investor in Imagr, a New Zealand intelligent-shopping-trolley developer; it identifies neither an Israeli security end-user nor defence, policing, border, prison, settlement, or military activity, and the relationship’s current status is unknown.²¹
• No qualifying relationship was verified; consequently, no physical downstream result, ownership or control level in a relevant supplier, commencement date, current or discontinued status, or Israeli security end-user is documented in the reviewed sources.^{1, 17, 20}

Logistical Sustainment & Base Services

• No public evidence identified of Starling providing transport, fuel, catering, waste, facilities, telecommunications, freight, port handling, or other logistical-sustainment services to Israeli military or security installations.^{1, 3, 6}
• Starling’s 2025 disclosures identify offices in Cardiff, London, Manchester, Southampton, and Dublin.^{22, 14}
• FY2026 reporting identifies offices in New York, Toronto, Dubai, and a new London headquarters, but does not identify an Israeli group operating location.^{1, 12, 13}
• The reviewed public record cannot establish the absence of confidential banking customers, undisclosed investments, or otherwise undisclosed transactions involving Israeli defence-related entities.^{1, 3}

Munitions, Weapons Systems & Strategic Platforms

• No public evidence identified that Starling group entities manufacture or supply weapons, ammunition, munitions precursors, lethal platforms, missile-defence systems, strategic systems, or critical military subsystems for Israeli end-users.^{1, 3, 15, 16}
• Starling’s reported AI-related use concerns customer service, fraud prevention, and banking operations; reviewed disclosures do not describe a kinetic, targeting, or weapons-related function.^{23, 6}
• Engine’s reviewed product description remains financial-services software rather than a product whose designed output produces a targeting decision or weapons effect.^{15, 16}

Export Licensing, Regulatory & Legal History

• No public evidence identified of Israeli-defence-related export-licence grants, denials, suspensions, revocations, sanctions or arms-control enforcement, arms-embargo investigations, or court proceedings involving a Starling product or service.^{1, 3, 6}
• In October 2024, the FCA imposed a £28,959,426 penalty on Starling for financial-crime systems-and-controls failings, including sanctions screening; the FCA described incomplete listed-person screening from 2017, inadequate cross-border-payment screening, and potential sanctions breaches identified during Starling’s subsequent review.^{24, 25}
• The FCA action does not identify Israel, Israeli defence entities, settlement activity, military procurement, Israeli sanctions evasion, or an arms-trade transaction, and is not evidence of an Israeli-defence nexus.^{24, 25}
• Starling stated that it completed re-screening and a back-book review and introduced additional safeguards; the FCA recorded third-party testing in November 2023 and March 2024 that found the respective customer and payment-screening systems effective and efficient.^{25, 26}
• Starling’s Help Centre lists the Gaza Strip and West Bank among territories from which it cannot accept inbound payments, but describes a payment-acceptance restriction rather than a defence, settlement, procurement, or military-supply policy.²³
• This payment restriction does not establish a Starling operation, contract, reseller, or supply relationship in occupied territory.²³
• Starling’s ethics statement says that the bank will not donate to a political party, politician, or party-political campaign group, while the statement does not address personal donations by directors, former directors, shareholders, or their associated vehicles.²⁷
• The bank’s published charity-partnership page identifies Sports Aid, the National Trust, Action for Children, and Smart Works, and does not identify an Israel-, Palestine-, settlement-, military-, or political-advocacy-linked recipient.²⁸
• A U.S. private foundation bearing the McPike-Zima name reported Harald McPike as a substantial contributor of $11 million in its 2015 Form 990-PF; the latest located IRS-recorded return, for fiscal year 2024 and filed in November 2025, reports $1.605 million in charitable disbursements and $56.117 million in net assets.^{29, 30}
• The accessible presentation of the 2023 and 2024 foundation returns did not render the complete itemised Part XV grant schedule; no recipient-level conclusion concerning Israel-, Palestine-, military-, settlement-, or political-advocacy-linked grants is documented from those materials.²⁹

Civil Society Scrutiny & Documented Investigations

• The supplied deterministic full-text pre-scan found no mention of Starling Bank in specified canonical materials, including 2023 and 2025 OHCHR settlement-database materials, the UN Special Rapporteur’s A/HRC/59/23 report, and listed PAX, Al-Haq, BankTrack, Who Profits, Amnesty, Human Rights Watch, and BDS materials.^{7, 8}
• This is a document-scoped finding and does not establish database-wide, market-wide, or transaction-level absence.^{7, 8}
• No public evidence identified of a documented boycott, divestment, institutional-exclusion, or corporate-response campaign specifically alleging Starling’s Israeli defence-sector supply-chain involvement.^{1, 3, 6}
• Companies House lists Starling’s current statutory directors as Colin Bell, Raman Bhatia, Julie Chakraverty, Declan Ferguson, John Mountain, Dan Olley, and Darren Pope; Mountain was appointed on 18 June 2026 and Olley on 1 July 2026.¹⁹
• Starling identifies Colin Bell as Chair and Raman Bhatia as Group CEO; Bell’s published biography records 16 years in the British Army and roles with the UK Ministry of Defence and NATO, but does not describe an Israeli military, Israeli defence-industry, or Israeli-state-security role.¹⁸
• Companies House records Starling Intermediate Holdings Limited as directly controlling more than 75% of Starling Bank Limited’s shares and voting rights, with rights to appoint or remove directors.³¹
• No public evidence identified in reviewed official biographies, Companies House records, canonical materials, and targeted searches of Israeli-defence-prime directorships, Israeli security-force roles, or material holdings in documented Israeli military/security suppliers by current Starling directors or executives.^{18, 19, 7, 8}
• The June 2026 admission particulars identify JTC Starling Holdings Limited as holding 37.5% of Starling Group Holdings’ shares and 40.9% of voting rights, while naming Chrysalis, Fidelity, Railpen, Qatar Investment Authority, Millennium Management, Goldman Sachs, Anne Boden, directors, employees, and employee-benefit trusts among other shareholders.¹