Revolut received preliminary conditional approval from the US Office of the Comptroller of the Currency to establish a national bank, the British fintech announced on Thursday 3 September, following a decision letter signed by the regulator on 2 September. The approval covers Revolut Bank US, National Association, to be headquartered in Stamford, Connecticut, and operate without branches. The OCC set initial paid-in capital at no less than $95 million, net of organisational and pre-opening expenses, and required the bank to maintain a tier 1 leverage ratio of no less than 10.0 percent throughout its first three years of operation. Revolut has 12 months to raise the capital and 18 months to open, after which the approval expires.
The decision followed an application filed on 10 March 2026, and represented the company's second attempt at a US banking licence after an earlier effort to obtain a California state charter did not proceed. Revolut has pursued a domestic charter as an alternative to operating through partner banks, an arrangement that limits a firm's ability to hold deposits directly and to set its own lending terms. Executives at the company have previously characterised a US charter as securing a seat at the table with American regulators. The approval arrived roughly six months after filing, a shorter interval than the multi-year timelines that have historically accompanied de novo national bank applications.
CONDITIONS AND CARVE-OUTS
The grant is preliminary and conditional rather than a charter in force. The OCC withheld final approval and authorisation to commence business pending satisfaction of all pre-opening requirements, and retained the right to modify, suspend or rescind the approval. The regulator excluded the proposed retail foreign exchange business from the scope of the approval entirely. Three further activities — foreign exchange forwards, merchant acquiring, and correspondent banking for foreign non-affiliates — may not commence until the OCC issues a written determination of no objection for each.
Those carve-outs are material to the commercial case for the charter, because they touch the cross-border and payments activities central to Revolut's existing revenue mix. The structure leaves the company with a chartered entity whose permitted activities at opening are narrower than its application contemplated, and with several supervisory determinations still to obtain on a case-by-case basis. The capital conditions are also more demanding than the general regulatory minimum, with the 10.0 percent leverage floor applying for a full three years rather than during an initial ramp-up alone.
REMAINING APPROVALS
Two further regulatory processes remain outstanding before Revolut Bank US can open. The Federal Deposit Insurance Corporation has not yet ruled on the application for deposit insurance, without which the bank cannot accept insured deposits. Separately, both US HoldCo and Revolut Group Holdings have applied to the Federal Reserve to become bank holding companies, a step that would bring the group's US structure under Federal Reserve supervision. Reuters reported that the company is targeting a launch in the first half of 2027 with a headcount of approximately 160, under chief executive Cetin Duransoy.
The sequencing means the OCC decision, while the most substantive regulatory milestone to date, does not by itself establish a timeline. The FDIC and Federal Reserve determinations will govern whether the first-half 2027 target holds, and the 18-month window imposes an outer limit on how long the approval remains available. For finance executives tracking the entry of European digital banks into the US market, the conditions attached to this approval — a hard capital floor, an extended leverage requirement, and four activities requiring separate clearance — indicate the terms on which such entry is currently being permitted.