The same way European EMIs sometimes call their services banking services, without actually being banks. In many places in the world, you can offer some bank-like services (such as accounts and cards) without being a bank. It doesn't make you a bank.Legal - Euro Pacific Bank
Euro Pacific Intl. Bank Inc. is licensed and regulated by the Office of the Commissioner of Financial Institutions (OCIF) in Puerto Rico as an International Financial Entity (license # IFE-033). Terms and Conditions Banking Products offered by Euro Pacific Intl. Bank Inc. Account Agreement for...europacbank.com
So they are licensed by the OCIF as a Financial Entity offering "Banking Products", but they are not a Bank?
Where does it say EPB is listed as a bank?Here is the link to the OCIF document - https://ocif.pr.gov/Consumidores/Lista Concesionarios/Entidades Financieras Internacionales.pdf
** NOTE - EPB listed as a "bank" along with other banks...
Here are the lists of banks:
Commercial banks: https://ocif.pr.gov/Consumidores/Lista Concesionarios/Bancos Comerciales.pdf
International banks: https://ocif.pr.gov/Consumidores/Lista Concesionarios/Entidades Bancarias Internacionales.pdf
I can only find EPB listed in the EFI list you linked before. EFIs are not banks.