SEBA "bank", SQ, Dukascopy, Sygnum ... You have to dig really deep to prove these are banks to, probably at the end, conclude that in fact they are not, but in fact EMIs Especially in jurisdiction like Switz, with a whole rainbow of financial licences.
We use the word *bank* too often too loose for entities that from the outside look like one.
However, there is one thing and one thing only that defines a *depository institution* (aka "a bank") : government monopolistic licence to have a liability category called deposit, on which it issues *new* money in the act of a loan distribution.
If it doesn't have a license to create miney by issuing new loans, it is not︀ a bank. All other properties, like having a word "bank" in its name, client accounts︁ being segregated & having ibans, institution having a swift code or not, having access to︂ central bank's clearing system, qualifying for deposit protection scheme, even having deposits, but not being︃ able to issue loans is completely irrelevant. It still isn't a bank.