Bunq’s U.S. banking bid fails on capital, oversight flaws

Bunq received a formal denial from the Office of the Comptroller of the Currency (OCC) on August 4, when its request for a U.S. national bank charter was rejected. The watchdog cited “significant supervisory and compliance concerns,” prompting the Dutch challenger to rethink its North-American rollout.

Broker-dealer license does not equal banking authority

The firm secured a FINRA-approved broker-dealer license in 2025, allowing it to sell investment products to U.S. retail clients. However, the OCC made clear that such capital-markets permission does not satisfy the requirements for a full-service banking charter.

National bank charters demand rigorous balance-sheet reviews, consumer-protection safeguards and strict deposit-insurance standards, all of which differ markedly from the distribution rights granted by a broker-dealer license.

Key regulatory gaps highlighted

The regulator flagged the lack of a transparent capital plan. $50 million initially pledged from CEO Ali Niknam’s personal funds was later revised to $58.3 million, with the source of the additional cash left vague.

Management experience also raised concerns. The OCC noted that senior oversight was proposed on a part-time basis across several entities, and that the team lacked deep familiarity with U.S. national banking law and unsecured credit products.

European profit trends did not translate well to the American market. Bunq’s earnings in Europe rely heavily on interest-rate movements, yet the OCC deemed its U.S. customer-growth forecasts and loan-loss reserves “unrealistic” given intense competition from established card issuers.

For fintechs, the episode illustrates that a robust European track record does not automatically satisfy U.S. supervisory expectations. Companies must build a locally grounded risk framework, rather than adapting an overseas model after launch.

Regulatory expectations for foreign entrants

U.S. authorities require unequivocal, fully verified capital sources and peer-reviewed credit-loss provisions. They also expect dedicated local executives with proven expertise in federal banking statutes and fiduciary duties.

Applicants must demonstrate a compliant BSA/AML program and present defensible acquisition cost assumptions for the American credit market.

Parallel setbacks: Bunq and Wise

Similar concerns arose with the UK-based payments firm Wise, whose attempt to obtain a non-depository trust charter was also denied. The OCC cited anti-money-laundering risks and insufficient leadership experience with U.S. banking law.