- Key insight: The OCC approved Revolut's de novo bank charter, but gated four product lines behind separate supervisory sign-offs, among them the leveraged currency trading business Revolut had asked the agency to clear.
- What's at stake: Revolut serves roughly 1 million U.S. customers through partner banks including Lead Bank and intends to move them to its own bank, raising the question of what a sponsor bank loses when a fintech client charters up.
- Expert quote: The OCC "approved the core bank but held back the more complex product lines," said Evey Guo of FS Vector. Her firm has not seen product-by-product staging as a formal condition in other recent charter approvals. No other charter the OCC granted this year gates individual products.
Overview bullets generated by AI with editorial review.
A federal regulator cleared Revolut to build a national bank in the United States on Wednesday, but it held back four of the products the British fintech wants to sell in the states.
The Office of the Comptroller of the Currency, or OCC,
However, the OCC said the company would need additional approval to offer four services: leveraged currency trading (day trading in foreign exchange), foreign exchange forwards (contracts that lock in an exchange rate for a future date), merchant acquiring (processing the card payments a business takes from its customers) and correspondent banking for unaffiliated foreign banks (holding dollar accounts for foreign banks outside Revolut's own corporate group).
Each of those four needs its own sign-off (a so-called supervisory non-objection) before Revolut can launch it. The decision letter does not say why the OCC held them back.
The OCC declined to comment. A spokesperson said the office does not comment on specific institutions.
The leveraged product is day trading in foreign exchange, according to Roman Goldstein, a partner at Klaros Group. It is not the everyday currency conversion Revolut already sells U.S. customers, which the approval covers.
"The OCC approved the core bank but held back the more complex product lines," Evey Guo, a principal at the regulatory advisory firm FS Vector, told American Banker.
"This kind of product-by-product staging as a formal condition is not something we've seen in other recent charter approvals," Guo added.
The other de novo bank charters the OCC has approved this year, including
When asked what Revolut is now planning for the products the OCC held back, a company spokesperson told American Banker they "are currently under development."
"We will continue to work with the OCC and regulators to make sure they are ready for launch in the U.S.," the spokesperson said.
What Revolut has, and what it still needs
The approval the OCC granted Wednesday is preliminary. Revolut's deposit insurance application is still under review at the Federal Deposit Insurance Corporation.
Also, its U.S. holding company and its British parent are both awaiting the Federal Reserve's decision on their applications to become bank holding companies.
Revolut said in
The OCC set conditions in the meantime: Revolut has to put at least $95 million of paid-in capital into the bank and hold a Tier 1 leverage ratio of at least 10% for its first three years.
That ratio means at least a 10th of the bank's assets has to come from its own capital rather than from borrowing or deposits.
OpenReserve, a proposed Salt Lake City digital-asset bank the OCC approved the same day, drew stiffer terms: Twelve percent and $210 million. Stephen Lybarger, the agency's senior deputy comptroller for chartering, signed both letters.
The two banks plan very different businesses. Revolut kept digital assets largely outside its bank, projecting less than 2% of revenue from them and telling the OCC it "does not intend to hold any digital assets on its balance sheet." OpenReserve is planning a stablecoin-issuing subsidiary.
The approval expires if Revolut does not raise the capital within 12 months or open within 18 months, which has been standard across the conditional approvals the OCC has granted so far.
The review that got Revolut here took 176 days, from a March 10 filing to Wednesday's decision. The OCC has decided on many recent charter applications within 120 days of a complete filing,
Revolut serves its
Lead Bank "continues to be a great partner to us and they will support us through the migration," the Revolut spokesperson said. "Our post-migration plans have not been finalized."
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Lead Bank did not immediately respond to a request for comment.
Foreign fintechs, in and out
Revolut is the
The agency has turned others away. It
Revolut's approval "should put to rest the narrative that the OCC shut the door on international applicants after Bunq and Wise," Andy Kampf, a partner at Klaros Group, told American Banker.
Entities that engage in legally permissible activities, "including those involving digital assets and other novel technologies, should have a path to becoming a national bank," Comptroller of the Currency Jonathan Gould said in
For U.S. banks, a
Banks "need to resolve the cross-border friction ASAP," Lau told American Banker. "Moving money out of a U.S. bank account still costs a fortune. That's the gap that Revolut can and will close for consumers."
A changed bar
The OCC waved off the only public objection to the charter. It received three comment letters and concluded they "do not raise any significant supervisory, Community Reinvestment Act, or compliance concerns," according to the decision letter.
Only one of the three is public,
Lee argued that Revolut's Community Reinvestment Act plan set no lending targets and that tying a nationwide digital bank's obligations to one Connecticut market gerrymandered the territory on which the OCC would grade it.
The OCC "has turned into an untransparent rubber-stamper of applications for national bank charters," Lee told American Banker, "while weakening and seeking to further weaken the Community Reinvestment Act."
He said Fair Finance Watch will oppose Revolut "every- and anywhere."
The approval shows how much U.S. bank chartering has changed, according to Todd Baker, a senior fellow at Columbia University's Richman Center for Business, Law and Public Policy.
Revolut "has had many compliance and risk management failures over the years that have been sanctioned by regulators in other countries," Baker told American Banker.
The Bank of Lithuania, which supervises Revolut's European banking arm, fined it €3.5 million in April 2025 for anti-money-laundering failures,
That was the fourth action Lithuania had taken against the company since 2022 and the largest by a wide margin.
"In the past, that alone would have been a major red flag that would have delayed or prevented a new charter from being issued," he said. "Clearly, that is no longer the case."
Those troubles have all been abroad, Baker said. Revolut has "no specific U.S. state or federal problems," he said, and that "may have led to more lenient treatment" than Wise got.
A major open question is what the Federal Reserve does next. U.S. law requires any company that controls a national bank to become a bank holding company.
The Bank Holding Company Act tells the Fed to weigh, in every case, how effective an applicant has been at fighting money laundering, "including in overseas branches,"
"It will be interesting to see if the Fed imposes any particular conditions related to Revolut's overseas compliance and risk issues," Baker said.
