US regulators reject Bunq’s bank charter bid
The rejection of Bunq’s application for a national bank charter by the US Office of the Comptroller of the Currency (OCC) in early August has revealed a major obstacle for European fintechs seeking to expand into the American market: regulatory recognition does not function as a passport. The Dutch digital bank’s bid was turned down on August 4, with the OCC citing “significant supervisory and compliance concerns”—a setback that demands a reassessment of how foreign financial institutions can grow across borders.
The OCC’s decision highlights a fundamental difference between European and US banking systems. Bunq had already obtained a FINRA-approved broker-dealer license in 2025, enabling it to sell investment products to US retail clients. However, a national bank charter requires far stricter standards: thorough balance-sheet oversight, deposit insurance compliance, and consumer protections that brokerage licenses do not address. The denial makes clear that approval in capital markets does not guarantee access to full banking operations in the US. Three key regulatory concerns emerged from the OCC’s feedback.
First, the agency questioned Bunq’s capital planning. Initially, the bank proposed securing $50 million from CEO Ali Niknam’s personal funds, later adjusting the plan to $58.3 million through corporate dividends. Yet the OCC found these funding sources unclear and insufficiently documented, exposing a broader issue: US regulators demand full transparency in capital sourcing, not just financial commitments on paper. Second, the OCC raised concerns about Bunq’s lack of local executive expertise in US national banking laws and unsecured lending—the foundation of its proposed credit model.
The regulator noted that oversight would be handled part-time across multiple entities, a structure that fails to meet the OCC’s requirement for dedicated, full-time leadership with deep knowledge of federal regulations. This reflects a broader trend: US banking authorities prioritize in-house experience over remote or hybrid management structures. The third issue involved Bunq’s unrealistic growth projections for customer acquisition and loan-loss reserves. The OCC determined that Bunq’s expansion assumptions did not account for fierce competition from established US card issuers.
European fintechs often rely on interest-driven profits, but US regulators insist on locally validated risk models rather than imported frameworks. The rejection shows that European market conditions do not automatically apply in the US. Bunq’s setback is not isolated. In 2024, the OCC also rejected an application from UK-based Wise, a cross-border payments firm, due to anti-money laundering compliance risks and inadequate leadership experience with US banking law.
Unlike Bunq, Wise sought a non-depository trust charter to access clearing systems without offering credit, but even this approach faced scrutiny over governance and risk controls. Both companies now plan to revise their applications to address the OCC’s concerns, indicating that compliance in the US requires fundamental restructuring, not minor adjustments. The OCC’s demands go beyond capital and leadership. Regulators require industry-tested credit loss provisions, justified acquisition costs for US credit markets, and strong Bank Secrecy Act/anti-money laundering programs. European fintechs accustomed to lighter oversight may underestimate these requirements.
The OCC’s position reflects a clear stance: US federal banking rules do not allow automatic adoption of European models. Instead, foreign entrants must develop locally adapted risk and compliance systems from the ground up. For European fintechs, the takeaway is straightforward: entering the US market is not about scaling an existing model but rebuilding operations to meet federal standards. Bunq’s rejection serves as a warning that brokerage licenses or European profitability do not replace national banking compliance.
Success will belong to those treating the US as a separate regulatory environment, one where transparency, local leadership, and strict risk management are essential. Both Bunq and Wise have indicated they will resubmit revised applications, but their experiences highlight ongoing challenges. The OCC’s feedback suggests that capital structure, executive knowledge, and market realism will remain critical for any foreign fintech pursuing a US banking presence. Without directly addressing these issues, even well-funded European challengers face the same obstacle: a rejection that forces a complete overhaul of their US strategy.
