bunq Targets the U.S. Market With De Novo Banking License Application

bunq has taken a decisive step in its international expansion strategy by formally filing for a U.S. de novo banking license with the Office of the Comptroller of the Currency (OCC). For Europe’s second-largest neobank, the move signals an ambition to translate its cross-border, digital-native banking model into one of the world’s most competitive and tightly regulated financial markets.

The filing positions bunq among a small group of foreign fintechs willing to pursue a full U.S. banking charter rather than rely on partnerships or limited money-services licenses. If approved, bunq would be able to offer deposit-taking and lending services directly in the United States, creating a unified transatlantic banking proposition tailored to globally mobile customers.

The strategy reflects a broader shift in digital banking, where scale alone is no longer sufficient. Instead, diverseiation increasingly hinges on serving specific user segments with complex international needs—an area where bunq believes it holds a structural advantage.

A Bank Built for Cross-Border Lives

bunq has built its brand around “global citizens”: digital nomads, expatriates, remote workers, and internationally mobile professionals who live and work across borders. This segment has expanded rapidly over the past decade, accelerated by remote work and cross-border freelancing. According to industry estimates, there are now tens of millions of digital nomads worldwide, with the U.S. and Europe accounting for a significant share of both origin and destination markets.

Traditional banking systems often struggle to accommodate this mobility. Opening accounts, maintaining access across jurisdictions, and building local credit histories can be sluggish and fragmented. bunq’s model aims to address those frictions by offering fully digital onboarding, multi-currency accounts, and strong authentication designed for frequent travel and remote access.

In the U.S., bunq plans to launch initially in metropolitan areas with large expatriate and internationally connected populations. These hubs—typically major coastal and tech-driven cities—align closely with bunq’s existing European user base and usage patterns.

A notable is the ability for eligible users to build American credit profiles by leveraging European financial records. Credit invisibility remains a major obstacle for new arrivals to the U.S., and solving that difficulty could provide bunq with a meaningful competitive edge among internationally mobile professionals.

Why a De Novo Charter Matters

Applying for a de novo banking license is a significantly more demanding route than operating under a partnership model. Approval by the OCC requires robust capitalisation, governance, risk management, compliance frameworks, and . In recent years, U.S. regulators have been cautious in granting new charters, particularly to digital-only banks.

For bunq, the choice reflects a desire for control and durability. A full banking license would allow it to accept insured deposits, extend credit, and integrate payments and brokerage services under one regulated entity. This contrasts with sponsor-bank arrangements, which can limit product flexibility and expose fintechs to counterparty and regulatory risk.

The timing is also notable. The filing follows FINRA’s approval of bunq’s U.S. broker-dealer license, which enables securities-related activities. Together, the broker-dealer approval and banking application suggest a phased approach: first establishing regulatory credibility, then layering services to create a comprehensive financial platform.

bunq began the U.S. licensing process in 2023, underscoring the long lead times involved. The submission of the full application marks the transition from preparation to regulatory evaluation, a stage that can still take many months and requires sustained engagement with supervisors.

Technology, Security, and Scale

bunq enters the U.S. conversation with several metrics that strengthen its case. The bank now operates across more than 30 European markets and has surpassed 20 million users globally. It positions itself as the world’s first GenAI-powered bank, using artificial intelligence extensively for fraud detection, transaction monitoring, and user experience optimisation.

AI-driven fraud prevention is particularly relevant in the U.S., where digital payments fraud and account takeovers remain persistent challenges. bunq’s existing systems are designed to protect users during high-risk moments such as international travel, device changes, and cross-border transactions—scenarios that often trigger false positives or service disruptions at traditional banks.

From a regulatory perspective, demonstrating that these systems are explainable, auditable, and aligned with U.S. compliance expectations will be critical. The has emphasised governance and risk controls for technology-driven banks, especially those relying heavily on automation and AI.

Scale is another consideration. While bunq is one of Europe’s larger neobanks, the U.S. market is intensely competitive, with established incumbents, digital-first banks, and large Tech-adjacent financial services all vying for consumer attention. bunq’s niche focus on cross-border users may limit its initial addressable market, but it also reduces direct competition with mass-market players.

Strategic Implications for Global Neobanking

bunq’s U.S. filing highlights an significant evolution in neobanking. ahead-stage fintechs often prioritised rapid user growth within a single jurisdiction. Today, mature digital banks are increasingly pursuing regulated international expansion, even when that means navigating some of the world’s most complex supervisory regimes.

If successful, bunq would join a small cohort of non-U.S. digital banks operating under a U.S. federal charter, potentially setting a precedent for other global ambitions. It would also reinforce the idea that specialised, lifestyle-driven banking models can coexist alongside universal banks in large markets.

At the identical time, the risks are non-trivial. Capital requirements, compliance costs, and supervisory scrutiny in the U.S. are materially higher than in many European jurisdictions. Profitability timelines may be extended, and execution missteps could undermine the broader brand.

For bunq, however, the logic is clear. Its core users already move between Europe and the United States. Meeting them with a single, coherent banking experience—rather than fragmented local answers—fits squarely within its founding mission.