A Test of Resilience: What Nubank and Revolut Will Face in the U.S. Market

Brazil's Nubank and the U.K.'s Revolut received preliminary approval in 2026 to obtain full banking licenses in the United States. Conquering this market will be a key test of their business models.

In September 2026, Nubank, Latin America's largest neobank, announced the launch of its operations in the U.S. Six years earlier—in 2020—Revolut had entered that market.

Neither bank holds a U.S. banking license; instead, they operate through a Missouri-registered lead bank, which now operates under the “Bank-as-a-Service” model, providing its full banking license and technology platform to foreign players looking to break into the U.S. market.

Lead Bank is Nubank’s only “window” into the U.S. For Revolut, it is the main—but not the only—fully licensed partner; the British neobank also uses the channels of other major players in the U.S. BaaS industry—Cross River Bank and Sutton Bank.

Currently, both banks offer the same range of services nationwide that customers have come to expect in the regions where they operate. These include debit and credit cards, accounts, money transfers, loyalty programs, and cryptocurrency transactions. There are no complex, secured loan products in their lineup.

This model is an interim solution. It was not until 2026 (Nubank in January and Revolut in September) that both banks received preliminary approval from the regulator—the Office of the Comptroller of the Currency (Office of the Comptroller of the Currency, OCC).

Both Nubank and Revolut took advantage of the Trump administration’s more lenient approach to allowing foreign banks and fintech companies access to the local market.

To obtain a full license, they will have to meet a number of standard regulatory and financial requirements set by the OCC:

— Within one year of receiving preliminary approval, they must capitalize their U.S. legal entity to the amount specified by the OCC; there is no uniform capital requirement.

— By that same deadline, they must become members of the Federal Reserve System by purchasing shares in the regional Federal Reserve Bank where they are registered. This will require neobanks to allocate approximately 6% of their authorized and excess retained earnings: half to be spent immediately on purchasing shares of their respective Federal Reserve Bank, and the other half to be held in reserve in case of requirements from the Federal Reserve.

— Both banks must purchase an insurance policy against fraud and embezzlement by employees, determining the coverage amount on their own based on the size of their business, and join the U.S. Federal Deposit Insurance Corporation (FDIC) deposit insurance system after undergoing an assessment of their business model, risk management, anti-money laundering practices, and so on.

Nubank’s initial capital requirements are more than five times higher than Revolut’s—$95 million versus $504 million. Nubank also has stricter capital adequacy requirements. Revolut must fund at least 10% of its assets with the highest-quality (typically equity) Tier 1 capital, creating an additional buffer against losses, while Nubank must fund 11%. In other words, the regulator assessed the Brazilian neobank’s business model as more capital-intensive and riskier at the outset.

A second complication limited Revolut’s capabilities in the U.S. market right from the start. The OCC did not include in its preliminary approval the ability to conduct foreign exchange transactions for retail customers, correspondent banking, or merchant acquiring. The neobank will need separate regulatory approval for these services. Currency transfers at the interbank exchange rate are the key feature that helped Revolut quickly gain popularity in the UK and the EU. The lack of correspondent banking will prevent Revolut from opening accounts for other banks and processing their transactions through its U.S. subsidiary, and without merchant acquiring, it will not be able to process business payments.

With 139 million customers, Nubank is now the leader in Latin America; in Brazil—its home market—it has become the largest private bank and serves 60% of the country’s adult population. In Mexico, it is the largest digital bank, and in Colombia, it ranks among the top five in terms of funds raised from the public.

Nubank offers its full range of banking services only in these three countries, but through a partnership with the Swiss Sygnum Bank (announced in September of this year) and through its Swiss subsidiary Nu Global, it is able to operate in 35 countries across the EU and Latin America without national banking licenses, offering customers multi-currency accounts in stablecoins, the ability to trade cryptocurrency, make payments with a virtual card, and send international money transfers.

According to Sky News, Nubank is currently in talks to acquire the neobank Monzo, Revolut’s main competitor in the UK. Monzo could be valued at £8–10 billion ($10.6 billion–$13.25 billion) in the deal. For Nubank, the acquisition would effectively grant it a banking license in the UK and the EU (from the Irish regulator) and mark the start of a new round in its battle with Revolut. Monzo’s customer base in the UK stands at 16 million, compared to Revolut’s 13 million.

Revolut has fewer customers worldwide than Nubank—just 80 million—but it leads its competitor in global reach: through partnerships with local players and limited licenses (for example, by entering local markets as a fintech platform), the neobank operates in 160 countries around the world.

Revolut plans to go public no earlier than 2028. During its most recent secondary offering in July of this year, the company was valued at $115 billion. Before going public, it intends to increase that valuation to $200 billion.

The United States is home to the largest national banking market; without it, the global “empires” of Nubank and Revolut would not be possible. According to Mordor Intelligence, the retail segment’s money supply will exceed $900 billion in 2026, while the corporate segment’s will be approximately $770 billion. By 2031, the former will reach $1.1 trillion, while the latter will approach the $1 trillion mark ($950 billion).

But at the same time, it is also one of the most complex banking markets. It is oversaturated with reliable players. These include giants such as JPMorgan Chase, Bank of America, Wells Fargo, and Citibank, with assets exceeding $1 trillion, as well as more than 4,000 community banks with strong ties to the regions where they operate, more than 4,000 credit unions, and hundreds of fintech companies with various specializations that cover every conceivable customer need.

Banking regulation in the U.S. is a “patchwork” of state laws and federal regulations, with requirements varying significantly from state to state, according to analysts at Chambers and Partners, a research firm specializing in U.S. law.

In other words, establishing automated compliance and a unified risk management system in this country will be much more difficult and expensive.

In addition, 34% of the population already has a digital bank account, and 48% prefer mobile banking channels. In other words, digital technology has made significant inroads into everyday banking. 76.4% of households have at least one credit card, meaning that the proportion of Americans without access to credit is small.

Acquiring new customers in the U.S. is expensive. For example, Chime, a major American neobank, spent $124 per person on customer acquisition in 2025. At the same time, for every $1 spent on acquiring a single customer, Chime expects to generate a margin of about $2.1. This is below the 4:1 benchmark, which experts consider optimal.

Monzo, Bunq, N26, BBVA, and HSBC have already failed in the U.S. market. But the management teams at Nubank and Revolut believe the risk is worth taking.

Entering the U.S. market is a “strategic step in Nubank’s transformation into a global digital financial services platform,” according to its founder and CEO, David Velez. Revolut CEO Nick Storonsky has called the U.S. market key to the neobank’s global expansion.

According to Nigel Morris, co-founder of Capital One and an investor in Nubank, the U.S. market will be the biggest prize in this bank’s global expansion, one that will outweigh any “conquest” of Europe.

Without a U.S. license, Revolut will also be missing the "icing on the cake" ahead of its IPO, according to Ivan Tikhononenko, head of the banking practice at Amond & Smith.

The U.S. market will serve as a litmus test for banks’ business models and expose their weaknesses. Revolut is a bank for everyday transactions, while Nubank focuses on lending, according to Oleg Tinkov, founder of Tinkoff Bank and an early investor in Mexico’s Banco Plata. In his view, Revolut could take market share away from Amex in the U.S., while Nubank will compete with Capital One, which specializes in retail lending.

“But generally speaking, there’s more money in the lending sector as a whole, and the U.S. market is, first and foremost, a lending market. In the U.S., I’d bet on Nubank; in Europe, on Revolut,” he concluded.

This article was AI-translated and verified by a human editor