You have already been told that all means were collected through the BBP. There are no payments in the blockchain (ICO-like, tokens <=> ETH), all transfers are direct. Hardly anyone will give wallet addresses for you. Is it reasonable to require this from a closed banking type project?
It seems to me that you walk along the edge without having a banking license calling yourself a bank. You are an ordinary payment-limited payment system (not a full license), not a bank.