Revolut filed with the OCC and FDIC on March 4 to establish Revolut Bank US, a national bank seeking to take deposits, issue credit cards, make loans, and connect directly to Fedwire and ACH. Nearly six months later, the application remains pending while federal regulators have conditionally approved or converted bank charters for Circle, Ripple, Coinbase, Paxos, BitGo, and several other crypto firms.
The comparison highlights a crucial regulatory distinction. Revolut's application seeks a full-service national bank license covering deposit accounts, card products, consumer and commercial lending, cross-border payments, and investment and trading services. Recent crypto approvals, by contrast, have been narrower in scope.
Different charters, different requirements
The OCC's December 2025 approvals for First National Digital Currency Bank and Ripple National Trust Bank, along with conversions for BitGo Bank, Fidelity Digital Assets Trust Company and Paxos National Trust, were national trust-bank approvals centered on custody, reserves, and digital-asset services. Circle's charter provides custody for the firm and a limited set of institutional customers. Coinbase National Trust Company offers digital-asset custody strictly to custody clients. World Liberty's trust bank issues and redeems its USD1 stablecoin and holds reserves, with the OCC noting the company has no plans to become an insured depository institution.
A full-service insured national bank like Revolut seeks carries substantially more regulatory scrutiny. Regulators must weigh capital and liquidity adequate to survive stress, credit underwriting and loss reserves for a lending book, and BSA and OFAC compliance. Community Reinvestment Act obligations and federal deposit insurance add further layers of review, along with an OCC judgment on whether the firm's management can run a US national bank safely.
The relevant comparison set
Three other companies pursued the same full-service insured bank charter Revolut wants. Nubank received preliminary conditional approval in January for a new national bank offering lending, deposits, and digital-asset custody. Upstart received similar preliminary conditional approval in July for a fully digital insured lender focused on consumer credit. The OCC denied bunq's application over issues with capital, management experience, profitability assumptions, and risk to the Deposit Insurance Fund, finding that the company's proposed leadership lacked sufficient US banking and credit-product experience and that financial projections were not adequately supported.
Compliance issues and regulatory scrutiny
Fair Finance Watch filed formal opposition to Revolut's application on May 7, citing the company's international compliance history and criticizing its Community Reinvestment Act plan. The Federal Reserve has pressed Revolut on BSA and OFAC obligations, the timeframe of its CRA plan, and its planned service to low- and moderate-income communities.
Lithuania's central bank fined Revolut €3.5 million in 2025 for anti-money laundering deficiencies found during a routine inspection, covering gaps in transaction monitoring and suspicious-activity detection. Regulators identified no confirmed money laundering, and Revolut says it has committed to corrective action.
Two possible paths forward
The bull case has Revolut eventually joining Nubank and Upstart with conditional approval, showing that a global fintech can become a US national bank if it fully satisfies capital, CRA, management, and compliance requirements. Under that path, more competition arrives in deposits, cards, remittances, and crypto-linked retail finance.
The bear case has Revolut's review dragging on, facing a bunq-style denial, or ending in withdrawal, while trust-bank approvals for crypto firms keep moving forward on their own separate track. In that scenario, the apparent boom in crypto banking would narrow considerably in practice, with custody and stablecoin infrastructure advancing under federal supervision while the door into deposit-funded, FDIC-insured banking remains difficult to enter.
Washington has genuinely opened federal banking infrastructure to digital assets this year. It has not yet decided how far it will open the older, harder door into full-service deposit banking, and Revolut's application is where that answer is being tested.
