The Status of Revolut’s Bid for a U.S. National Bank Charter: A Comprehensive Overview

Revolut’s Ambitious Application for Full-Service Banking in the U.S.

Comparing Revolut’s Application to Recent Crypto Bank Approvals

Insights from Other Fintechs: The Path to Full-Service Bank Charters

The Controversial Review Process: Challenges Facing Revolut

The Future of Revolut: Potential Outcomes and Implications for the Banking Landscape

Revolut’s Bid for U.S. Banking License Stalls Amid Regulatory Scrutiny

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On March 4, 2025, Revolut, the fintech giant known for its innovative banking solutions, submitted an application to the Office of the Comptroller of the Currency (OCC) and the Federal Deposit Insurance Corporation (FDIC) to establish Revolut Bank US. This proposed national bank aims to offer a full suite of services, including taking deposits, issuing credit cards, making loans, and facilitating direct connections to Fedwire and ACH systems. Nearly six months later, however, the application remains under review, raising questions about the regulatory landscape for digital banking.

While Revolut’s application sits in limbo, federal regulators have been busy approving or converting bank charters for several cryptocurrency firms, including Circle, Ripple, and Coinbase. Unlike these crypto-focused approvals, which often center on narrower services like custody and reserves, Revolut’s application seeks a comprehensive banking charter, making its review a more complex undertaking.

A National Bank with Ambitious Goals

Revolut’s vision for its U.S. operations is ambitious. The company aims to establish a full-service digital national bank that supports deposit accounts, card products, consumer and commercial lending, cross-border payments, and investment services. With over 70 million customers across 40 markets and a valuation of $75 billion, reached in a secondary offering in November 2025, Revolut is keen to reduce its reliance on partner banks and expand its footprint in the U.S. market.

However, the application must navigate a rigorous review process. Regulators are tasked with assessing Revolut’s capital and liquidity, credit underwriting, compliance with the Bank Secrecy Act (BSA) and Office of Foreign Assets Control (OFAC), and adherence to Community Reinvestment Act (CRA) obligations. The stakes are high, as federal deposit insurance adds exposure to the Deposit Insurance Fund, a layer of protection that crypto trust charters do not carry.

The Crypto Approval Landscape

In contrast to Revolut’s comprehensive application, many of the recent approvals for crypto firms have been for national trust banks, which focus on custody and digital-asset services rather than full deposit banking. For instance, Circle’s charter is limited to custody for its affiliates and select institutional clients, while Coinbase National Trust Company offers digital-asset custody strictly to custody clients.

Other firms, like World Liberty and Bridge, have received trust bank charters that explicitly state they do not intend to become insured depository institutions, thereby sidestepping CRA requirements. This distinction highlights the unique challenges Revolut faces in its pursuit of a full-service banking license.

A Tough Comparison

Revolut’s application is not without its challenges. Three other companies have sought similar full-service insured bank charters, with varying outcomes. Nubank received preliminary conditional approval in January for a national bank offering lending, deposits, and digital-asset custody, while Upstart followed suit in July. Conversely, bunq’s application was denied due to concerns over capital, management experience, and profitability assumptions.

This comparison underscores the rigorous standards the OCC applies to full-service banking applications, making Revolut’s journey all the more critical to watch.

Regulatory Hurdles and Opposition

The review process for Revolut has not been smooth. Fair Finance Watch filed formal opposition to the application in May, citing concerns about the company’s international compliance history and its CRA plan. Additionally, the Federal Reserve has pressed Revolut on its BSA and OFAC obligations, as well as its commitment to serving low- and moderate-income communities.

Revolut’s compliance history has also come under scrutiny; in 2025, Lithuania’s central bank fined the company €3.5 million for anti-money laundering deficiencies. Although no confirmed money laundering was identified, the incident has raised red flags for U.S. regulators.

The Path Forward

As the OCC navigates this complex landscape, the outcome of Revolut’s application could have significant implications for the future of digital banking in the U.S. A successful approval could pave the way for increased competition in deposits, cards, and crypto-linked retail finance, contributing to the broader narrative of a “crypto banking boom.”

Conversely, a prolonged review or a denial could signal a tightening of the regulatory environment for fintechs seeking to enter the traditional banking space. As the OCC balances its commitment to fostering innovation with the need for stringent oversight, Revolut’s application remains a litmus test for the future of digital banking in America.

In a year where Washington has opened its doors to digital assets, the question remains: how far will it go in embracing full-service banking for fintechs like Revolut? The answer lies in the ongoing review of this pivotal application.