Revolut Has Preliminary Approval for a US National Bank. Four of Its Businesses Were Left Out of It.

The Office of the Comptroller of the Currency has given Revolut preliminary conditional approval to organise a full-service digital national bank in the United States. The decision is dated September 2, 2026, and covers Revolut Bank US, National Association, of Stamford, Connecticut, a subsidiary of Revolut Holdings US, Inc., which sits under UK-based Revolut Group Holdings Ltd.

Preliminary conditional approval is a permission to start building a bank, not a permission to open one. The OCC's decision says plainly that final approval and authorisation to open will not be granted until all pre-opening requirements are met. Federal Reserve and FDIC steps sit outside this document.

What the Conditions Require

• Minimum initial paid-in capital of $95 million, net of organisational expenses.
• A tier 1 leverage ratio of no less than 10.0% throughout the first three years of operation.
• Sixty days' written notice before any significant deviation from the submitted business plan, with an OCC written determination of no objection, for three years after opening.
• Prior OCC approval of senior executive officers and directors, expressly including the chief compliance officer, Bank Secrecy Act officer, chief technology officer and chief information security officer.
• Capital raised within 12 months and the bank open within 18 months of approval, or the authorisation expires.

The Carve-Outs

Four business lines were not cleared to launch with the charter. Before offering foreign exchange forwards, merchant acquiring, or foreign non-affiliate correspondent banking, the bank must obtain a separate OCC written determination of no objection. Retail foreign exchange is handled the same way: the decision requires the bank to submit information for OCC supervisory non-objection before commencing a retail foreign exchange business.

That matters because foreign exchange is close to the centre of what Revolut is known for. The charter approves the bank; it does not approve that part of the product set.

Digital Assets Are In the Plan, in a Narrow Form

The OCC's decision confirms the bank may provide digital asset custody in a non-fiduciary capacity, delivered through a UK affiliate, and reaffirms the agency's prior determination that custody services including cryptocurrency custody are permissible for a national bank. Crypto custody is projected at under 2% of revenue. The bank may market stablecoins and give customers access to them through third-party issuers, but would not itself issue a stablecoin or manage reserves. Remittance services using digital assets are also in scope.

One pre-opening requirement points at the same area: the capital plan must address material risks including off-balance-sheet risk arising from digital asset custody. Others cover an independent external audit, third-party penetration testing of the electronic banking platform, and submission of the full information systems architecture for pre-opening review.

Who Runs It

The OCC approved Cetin Duransoy as chief executive, organiser and director; Josh Van Hulst as chief compliance officer and organiser; Robert Treadwell as chief financial officer and organiser; and Siddhartha Jajodia, Bruce Wallace and Alice Cho as directors. Further organisers and officers need approval before opening. A residency waiver was granted for the whole board and remains revocable at the agency's discretion.

Conditional OCC approval is an important first step towards establishing the proposed Revolut Bank US.