It has been a long, winding road for Revolut in the United States. After hitting a wall with their California state bank charter application back in 2023—a move largely derailed by regulatory friction and internal-control headaches—the London-based fintech is finally back in the game. They have secured preliminary conditional approval from the Office of the Comptroller of the Currency (OCC) for a national bank charter, making them the first European neobank to reach this stage while actively running a stablecoin business.
This isn’t exactly a victory lap, though. As detailed in the OCC Corporate Decision #1390, the regulator has handed down a list of conditions that would make any compliance officer sweat. Revolut is looking at a $95 million paid-in capital requirement to be cleared within a year. Even more demanding is the mandate to maintain a Tier 1 leverage ratio of at least 10% for the first three years—double the standard 5% hurdle for traditional banks. It is a high-stakes regulatory trial, not a free pass.
The real intrigue here isn’t the license itself, but the operational blueprint the OCC has signed off on. Revolut isn’t positioning itself as a stablecoin issuer. Instead, the bank is authorized to market Revolut-branded stablecoins, provide customer access, and manage custody through a technology affiliate. The actual token issuance is offloaded to a third party. This is a “distribution-first” model, a structure that aligns quite neatly with the emerging framework of the GENIUS Act.
This strategy is essentially a carbon copy of what Revolut has been doing in Europe. Back in August 2026, the company rolled out EURR, a MiCA-compliant euro stablecoin, across Denmark, Poland, and Portugal. In that setup, the token is issued by Bridge Building S.A.—a Stripe subsidiary—while Revolut handles the distribution. By importing this “Issuance-as-a-Service” architecture to the US, Revolut sidesteps the heavy regulatory burden of being the primary issuer, pushing the reserve management and compliance heavy lifting onto a specialized partner.
The timing of this approval is particularly spicy given the current regulatory calendar. The GENIUS Act, which became law in July 2025, hits its enforcement date on January 18, 2027. As we noted in our coverage of the GENIUS Act Compliance Cliff, the seven primary regulators missed their initial rulemaking deadlines, though OCC Acting Chief Gould has promised a final rule by November 2026. With Revolut targeting a US launch in the first half of 2027, they are essentially building their US infrastructure while the federal stablecoin regime is still being poured into the mold.
This development lands in a crowded, contentious room. We have already seen five trust bank charters approved for players like Circle, Ripple, and Paxos, a trend that has drawn sharp criticism from the Conference of State Bank Supervisors (CSBS) over concerns of regulatory arbitrage. Revolut’s national bank charter path is distinct, yet it inevitably invites comparison to the broader industry push for stablecoin legitimacy, including the ongoing discussions surrounding the 21-bank stablecoin consortium. As reported by PYMNTS and covered by FF News, the industry is clearly watching how these different charter paths interact with federal oversight.
Nik Storonsky, Revolut’s founder and CEO, framed the approval as a foundational step.
Conditional OCC approval is an important first step towards establishing the proposed Revolut Bank US. It gives us the foundation to build in the world’s largest financial market and bring the full Revolut experience to millions of Americans.
Yet, the “full experience” remains a work in progress. Four critical product lines—leveraged currency trading, FX forwards, merchant acquiring, and correspondent banking—still require further supervisory non-objection before they can go live.
Ultimately, Revolut’s conditional charter represents a pragmatic evolution in bank-fintech convergence. By acting as the regulated interface for third-party stablecoins, they are betting that the future of digital assets lies in distribution and custody rather than the risky business of direct issuance. Whether this model satisfies the final, yet-to-be-seen OCC rules remains the central question for the first half of 2027.