Revolut’s US Bank Charter Application Remains Pending Amid Wider Crypto‑Banking Approvals

Revolut submitted an application to the Office of the Comptroller of the Currency (OCC) and the Federal Deposit Insurance Corporation (FDIC) on March 4, 2024, seeking a national bank charter that would allow it to take insured deposits, issue credit cards, make loans and connect directly to Fedwire and ACH.

Scope of Revolut’s Request

The company describes the proposed institution as a full‑service digital bank offering deposit accounts, card products, consumer and commercial lending, cross‑border payments and investment and trading services. Revolut serves more than 70 million customers in 40 markets and cites a $75 billion valuation.

Regulatory Landscape

During the same period, regulators have conditionally approved or converted charters for crypto‑focused firms such as Circle, Ripple, Coinbase, Paxos, BitGo and others. Those approvals are generally limited to digital‑asset custody, stablecoin issuance or narrow trust‑bank activities and do not include FDIC‑insured deposit taking or consumer lending.

Comparison with Other Fintech Applicants

• Nubank: Received preliminary conditional approval for a full‑service insured national bank; still requires FDIC insurance and final pre‑opening approvals.
• Upstart: Granted preliminary conditional approval for a digital insured lender focused on consumer credit.
• bunq: Application denied due to capital, management experience, profitability assumptions and potential risk to the Deposit Insurance Fund.

Revolut’s application falls into the same “full‑bank” lane as Nubank and Upstart, rather than the narrower trust‑bank charters granted to many crypto firms.

Opposition and Compliance Concerns

Fair Finance Watch filed formal opposition on May 7, 2024, citing Revolut’s international compliance history and its Community Reinvestment Act (CRA) plan. The Federal Reserve has questioned the company’s Bank Secrecy Act (BSA) and Office of Foreign Assets Control (OFAC) compliance, as well as its timeline for CRA obligations. Lithuania’s central bank fined Revolut €3.5 million in 2025 for anti‑money‑laundering deficiencies, though no confirmed money‑laundering was identified.

Possible Outcomes

1. Conditional approval: Revolut joins Nubank and Upstart, gaining a full‑service insured bank and expanding competition in deposits, cards and crypto‑linked retail finance.
2. Extended review with conditions: The application remains pending while regulators request additional information on capital, liquidity, management and compliance.
3. Denial or withdrawal: Mirrors bunq’s outcome, limiting the crypto‑banking narrative to custody and stablecoin infrastructure.

The pending decision highlights a two‑tier system: rapid approvals for crypto‑focused trust charters versus a slower, more stringent process for full‑service insured banks.