Dutch Neobank Files for a US De Novo Banking License

Europe’s second largest neobank bunq has formally filed for a US de novo banking license with the Office of the Comptroller of the Currency (OCC). The Dutch-based firm had previously applied for a banking license with the FDIC in April 2023, but later withdrew its initial application due to a misalignment in supervisory expectations between US and Dutch regulators in early 2024.

Bunq says that its U.S. offering, like its EU one, will focus on "digital nomads and global citizens with ties to both Europe and the U.S." Should the OCC approve its application, bunq plans to launch first in areas with large expat communities to allow expats to open and manage both US and EU accounts in one app.

For context, a de novo banking license is a charter for a brand-new entity, rather than the acquisition or branching out of an existing bank. For bunq, this effectively means completely restarting the path toward having a fully regulated U.S. banking presence. By contrast, expansion for non-US fintechs into the US usually happens via acquisitions or partnerships rather than charters. However, applying for a charter bid means that bunq intends to start from scratch in the country, which implies it is aiming for more control over its product stack, reduced dependence on sponsor-bank relationships, and greater credibility with business customers.

Non-US neobanks currently face significant challenges entering the US market due to high competition from established players and a regulatory environment that’s very different to that of the EU. There’s often a major gap between charter timelines and fintech growth cycles too, which can result in longer time-to-market and poor unit economics.

Bunq’s application for a de novo banking license, while undoubtedly ambitious, signals a newer trend where fintechs are seeking greater regulatory durability as the cost of sponsor-bank partnerships and compliance uncertainty rises. As risk (and costs) go up, fintechs must consider market diversification and longer-term licensing strategies if they want to operate like banks and take market share from the incumbents. For EU or UK fintechs planning to expand into the US market, obtaining a banking charter isn’t just a license—it also requires an operating model change, hence bunq’s decision to start from the beginning.