Third-Party Assessment of Starling Bank Customer On-Boarding

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Third-Party Assessment of Starling Bank Customer On-Boarding


Holistic AI conducted an audit of Starling Bank’s on-boarding system, focusing on the face verification component. Their digital onboarding process is the front door to this digital bank, and this component ensures the soundness of their KYC process. Holistic AI produced an Audit report that Starling Bank used to fulfil their requirements with respect to BCR as well as their duty to customers.


To be able to provide a valid third-party assessment of a face verification software, without having access to customer data as well as being least invasive as possible to their technology infrastructure. Both criteria are relevant, given that a bank has compliance requirements above most other industries.


Holistic AI used its well-recognized methodology of Levels of Auditability, where a balance is strike between the disclosure and feedback provided in an audit. We requested Level 2 access, meaning access to the API of the different components involved in the onboarding process.


  • A report that can be shared with BCR and uses the best research literature and practices around face verification testing and assurance.

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