A FINRA Licence Wasn’t Enough: Bunq’s US Bank Charter Just Got Rejected

Fintech can scale software globally. Banking licences do not travel that easily.

The US Office of the Comptroller of the Currency rejected Dutch fintech Bunq’s application for a national bank charter, citing significant supervisory and compliance concerns.

The regulator questioned several practical pieces of the US plan: how Bunq would be capitalised, whether management had enough experience with unsecured credit cards, and whether the proposed bank could operate safely and reach profitability in the US market.

That is interesting because Bunq already secured a FINRA-approved broker-dealer licence in 2025 allowing it to offer investment products in the US. A securities licence did not automatically translate into approval to become a bank.

This is a useful framework for fintech—and crypto.

“Regulated” is not one universal status. Brokerage, banking, custody, payments and digital assets can each require different permissions, capital structures and compliance systems.

Bunq says it plans to address the OCC’s concerns and continue pursuing a US presence.

The story is not “America banned Bunq.” It is that the current banking plan failed the regulator’s test.

Which is harder for global fintechs to localise: the product, the balance sheet or the compliance culture?