Revolut received preliminary conditional approval from the Office of the Comptroller of the Currency for a national bank charter, in a decision dated 2 September and announced by the company on Thursday 3 September. The approval covers the proposed Revolut Bank US, N.A., to be headquartered in Stamford, Connecticut, and staffed by approximately 160 employees at launch. The OCC set minimum paid-in capital of $95 million and required the institution to maintain a tier 1 leverage ratio of no less than 10% for its first three years of operation. Revolut has said it intends to begin operating as a standalone, federally regulated bank in the United States in 2027.
The decision follows Revolut's earlier, unsuccessful attempt at a US licence, and a renewed application filed in March with both the OCC and the Federal Deposit Insurance Corporation. It also comes months after the London-based group secured a UK banking licence, ending a protracted authorisation process with British regulators. Revolut has framed a US charter as strategically necessary rather than incremental, describing direct regulatory standing as a seat at the table alongside incumbent institutions. The group reported record pre-tax profits of $1.4 billion for 2024 and has passed 80 million retail customers across 40 countries.
THREE APPROVALS STILL OUTSTANDING
The OCC's action is preliminary and conditional, and does not by itself permit Revolut to accept deposits in the United States. A statement issued by the company on 3 September identified three further decisions required before the bank can open: FDIC approval of deposit insurance, Federal Reserve approval of the holding-company structure, and final sign-off from the OCC once organisational conditions are met. Each of these is a separate review on its own timetable, and none is automatic once a preliminary charter approval is in hand.
That sequencing places meaningful distance between the current approval and a functioning US bank. Preliminary conditional approvals of this kind typically require the applicant to raise the specified capital, install a full board and management team, complete operational readiness testing, and satisfy examiners before the charter is issued in final form. Revolut's stated target of a first-half 2027 launch assumes the remaining federal reviews conclude without material delay.
RETAIL FOREIGN EXCHANGE CARVE-OUT
The OCC withheld authorisation for several activities central to Revolut's commercial identity, most notably retail foreign exchange. The agency also declined at this stage to approve merchant acquiring and foreign correspondent banking, requiring separate sign-off before those lines can be conducted through the national bank. The carve-out is significant because low-cost currency conversion was the product that built Revolut's original customer base and remains a defining feature of its European proposition. The approved entity is, for now, permitted to operate a materially narrower business in the United States than the one Revolut runs elsewhere.
For finance executives, the decision is a test case in how quickly a foreign-owned digital institution can move through the US chartering process, and on what terms. The conditions attached — an elevated leverage floor, a defined capital minimum, and activity restrictions on the group's signature product — indicate that speed has been traded against scope. The material questions now are whether the FDIC and the Federal Reserve reach the same conclusion as the OCC, and whether Revolut can obtain the additional activity approvals it needs to make the US entity commercially comparable to its operations in Europe.