Revolut now holds a United States national bank charter approval and, for the moment, no permission to run the business that made its name. The Office of the Comptroller of the Currency (OCC) granted preliminary conditional approval to Revolut Bank US, National Association on September 2, 2026, in Corporate Decision #1390. Page 1 of that eight-page letter is unambiguous: “This preliminary conditional approval does not include the proposed retail foreign exchange business.”
The size of what has been fenced off is easy to underplay. Note 6 of Revolut Group Holdings Ltd’s 2025 annual report, page 121, records foreign exchange fee income of £605.8 million for the year, up 43 percent from £422.2 million in 2024 and equal to 17.7 percent of the group’s £3.43 billion of total fee income. Cheap currency conversion is the product most associated with the Revolut brand in Europe. It is also the one the OCC has deliberately held back.
What Corporate Decision #1390 actually says
The bank must obtain a written supervisory non-objection under 12 CFR 48.4 before it can commence a retail forex business. That citation is correct and it matters: Part 48 of Title 12 is the OCC’s Retail Foreign Exchange Transactions rule, and section 48.4 requires a national bank to satisfy the agency on customer due diligence, new product approvals, non-cash margin haircuts and conflicts of interest before it starts.
Retail forex is not the only carve-out. Condition 4, on page 4, separately bars the bank from offering Foreign Exchange Forward, Merchant Acquiring or Foreign Non-Affiliate Correspondent Bank products without a further written determination of no objection. Currency risk is therefore gated twice over — once at the retail counter, once in the forwards book.
The rest of the decision is a conventional de novo package. The organizing group filed on March 10, 2026 under 12 USC 21–27 and 12 CFR 5.20 for a full-service insured national bank in Stamford, Connecticut with no branches (page 2). Condition 2 requires a tier 1 leverage ratio of no less than 10.0 percent throughout the first three years of operation. Initial paid-in capital, net of organizational and preopening expenses, must be at least $95 million. Capital must be raised within 12 months and the bank must open within 18 months — a March 2028 backstop — or the approval expires. The OCC received three comment letters. Senior Deputy Comptroller Stephen Lybarger signed it.
The staging is the news
“This kind of product-by-product staging as a formal condition is not something we’ve seen in other recent charter approvals,” Evey Guo, Principal at FS Vector, told American Banker, adding that the OCC “approved the core bank but held back the more complex product lines.” Todd Baker, Senior Fellow at Columbia University’s Richman Center, was blunter about the applicant’s record, telling the same outlet that Revolut “has had many compliance and risk management failures over the years that have been sanctioned by regulators.”
Revolut’s own framing skips the carve-outs entirely. US chief executive Cetin Duransoy — listed in the decision as an organizer, CEO and director — said the company is “grateful for the OCC’s open and transparent dialogue throughout this process” and that the ruling keeps Revolut on track for a 2027 launch. Founder Nik Storonsky called it “an important first step towards establishing the proposed Revolut Bank US,” per the company’s September 3 announcement. Neither statement mentions foreign exchange. The OCC declined to comment on a specific institution.
A three-year queue of charter hopefuls
Context matters here. In September 2023 this publication reported that US regulators had no Revolut banking licence application on file at all; the company reached preliminary approval 176 days after finally filing. It arrives into a crowded queue. Mercury cleared an OCC national bank charter in May, Klarna filed to end its WebBank reliance in July, and Nubank has been pushing its own US charter case. Revolut also won an Australian ADI licence in July, making this its second prudential approval of 2026.
For trading desks the read-through is narrow and specific. Revolut can open a US bank with deposits, cards, lending and digital-asset custody while its leveraged currency offering sits outside the perimeter, subject to a filing the OCC has given no deadline to review. That is a materially different competitive posture from incumbent US retail brokers operating under the existing 30:1 retail FX leverage regime. Expect the 12 CFR 48.4 submission, not the FDIC or Federal Reserve applications, to be the gating item watchers should track — because it is the only one that decides whether the US Revolut looks anything like the European one.
Rick Steves
Rick Steves has seen business and economics through many lenses. He joined the financial services industry in 2009, and has been a financial journalist since 2011. He holds a degree in Business Administration and has experience producing real-time news, from both buy-side and sell-side, as well as for retail traders, brokers and service providers. Steves' work has appeared in a variety of online publications including FX Street, NewsBTC, FinanceFeeds, and The Industry Spread. Rick has great interest in the dynamics of the trading industry. The never-ending clash between technology, economics, regulation, and more importantly, the people.
