Revolut Granted National Bank Charter, Subject to Extra Regulatory Approvals
British fintech Revolut has been authorized by the US Office of the Comptroller of the Currency (OCC) to establish a national bank, Revolut Bank US, N.A., headquartered in Stamford, Connecticut. This marks a significant milestone as Revolut prepares to offer full banking services on its own license in the US market. However, the OCC has stipulated that four specific business lines require separate regulatory non-objection letters before they can be launched.
The OCC’s approval letter details that Revolut must seek additional clearance for leveraged forex trading (including intraday forex), foreign exchange forward contracts, merchant acquiring services (processing card payments for merchants), and correspondent banking services for unaffiliated foreign banks holding US dollar accounts. The regulator has not publicly clarified the rationale for postponing approval of these segments.
Revolut representatives stated that these four business lines are still in development and that the company remains committed to close engagement with the OCC and other US regulators to ensure compliance with domestic regulatory expectations.
Capital Requirements and Ongoing Regulatory Steps
The OCC approval represents a conditional stage, with Revolut still awaiting deposit insurance coverage from the Federal Deposit Insurance Corporation (FDIC). Additionally, the company’s US holding entity and UK parent await the Federal Reserve’s bank holding company status approvals. Revolut plans to commence operations by 2027.
The OCC has mandated a minimum capital injection of $95 million and requires Revolut to maintain a Tier 1 leverage ratio of no less than 10% for the initial three years. By comparison, OpenReserve, a digital asset bank recently approved on the same day, must meet a higher 12% leverage ratio and hold $210 million in capital.
Revolut’s application process spanned 176 days, somewhat longer than other comparable fintech approvals this year, which typically concluded within 120 days. For instance, Nubank received approval in just 121 days.
Transition Strategy and Competitive Landscape
Currently, Revolut serves approximately one million US customers through partnerships with third-party banks such as Lead Bank in Missouri. The company intends to migrate these users onto its national bank charter gradually. Revolut has confirmed that Lead Bank will continue to support this customer transition, though precise arrangements are still being finalized. Lead Bank declined to comment.
Market analysts specializing in US and Canadian fintech view Revolut’s independent charter as reducing reliance on third-party bank licenses. Industry observers note that this development introduces new competition pressures for established US banks while highlighting complexities in cross-border financial services.
Foreign Fintechs and US Regulatory Environment
Revolut follows Nubank as the second foreign fintech to secure a US national bank charter, signaling a potential shift in OCC’s approach to international applicants. In contrast, other prominent foreign fintech firms such as Wise and Bunq have faced rejection in their US banking license applications.
OCC Comptroller Jonathan Gould has emphasized the importance of accommodating innovative financial enterprises, including those involved with digital assets, to foster compliant banking relationships.
Compliance Issues and Regulatory Scrutiny
Revolut has encountered regulatory challenges in Europe, notably a €3.5 million anti-money laundering fine from Lithuanian authorities. Industry sentiment previously suggested such issues might hinder US banking approvals. However, these concerns did not evidently impede the current OCC decision. Todd Baker, a senior legal researcher at Columbia Law School, remarked that the overseas nature of the regulatory infractions and the absence of significant US legal disputes likely contributed to a more accommodating review.
The Federal Reserve’s forthcoming decision on Revolut’s bank holding company status will be closely scrutinized, particularly for any enhanced anti-money laundering obligations.
Public Feedback and Policy Context
During the approval process, the OCC received only three public comment letters. Critics questioned the absence of concrete lending targets within Revolut’s Community Reinvestment Act plans, though these concerns did not affect the charter’s issuance. Some opponents raised issues over the transparency of OCC’s review process.
This approval reflects evolving standards for granting US banking licenses, illustrating regulatory efforts to balance innovation with risk mitigation in a complex financial landscape.