SOUTH BRONX / SDNY, Sept 4 – Revolut
applied to the Office of the Comptroller of the Currency
to charter a national bank and to the Federal Reserve to
become a bank holding company. On September 3, Revolut
bragged about OCC approval - but as of 4 pm the OCC had
put nothing on its website, nor emailed commenter Inner
City Press, beyond belatedly denying its FOIA request by
withholding 1000 pages, since appealed. OCC FOIA denial,
acknowledging 1000 pages withheld, on DocumentCloud here.
On September 4, two days after Revolut
announced OCC approval and one day after Inner City Press
revealed the OCC had withheld 89 percent of its own FOIA
production on the application, the Federal Reserve has
sent Revolut Holdings Ltd. and Revolut Holdings US, Inc. a
further round of questions on their bid to become bank
holding companies — and this time, unlike the Fed's May 21
letter, which was copied openly to Fair Finance Watch and
quoted questions about BSA/OFAC compliance, the CRA
Strategic Plan timeline, and low- and moderate-income
lending in full, the substantive questions are confined to
a Confidential Annex.
The shift is worth noting on its own terms.
In May, the Fed asked Revolut in public, cc'd
correspondence to explain how it would meet Bank Secrecy
Act and OFAC obligations, given Revolut's fourth major
European anti-money-laundering enforcement action in three
years, fines escalating from €50,000 in 2022 to a record
€3.5 million in April 2025. Whatever the Fed is asking
now, on the same underlying compliance questions, the
public can no longer see it. Fair Finance Watch and Inner
City Press have filed a FOIA request for the Confidential
Annex — the ninth documented instance this year of the
Board withholding its own questions to a merger or charter
applicant, joining OppFi, Bank of Nova Scotia and Enova,
on which Inner City Press has filed a FOIA lawsuit to be
heard Sept 10.
Fair Finance Watch, with Inner City Press
on the FOIA, filed opposition to Revolut's
application, citing among other things that
"in April 2025, the Central Bank of
Lithuania — Revolut's primary European banking regulator —
fined Revolut Bank a record €3.5 million, the maximum
penalty available, for systematic weaknesses in its
anti-money laundering monitoring processes. Regulators
found that Revolut's systems were insufficient to detect
patterns indicating money laundering or terrorist
financing. This was the fourth major enforcement action
against Revolut since 2022, with fines escalating from
€50,000 in 2022 to €3.5 million in
2025."
FFW also noted that "Public Exhibit 5 of
Revolut's FDIC application — its proposal to develop a CRA
Strategic Plan pursuant to 12 C.F.R. § 25.27 — is a
joke."
On May 21 the Fed finally asked Revolut
some questions, cc-ing FFW:
"1. Describe how US HoldCo will fulfill its
Bank Secrecy Act (“BSAâ€) and Office of Foreign Assets
Control (“OFACâ€) obligations, including with respect to
suspicious activity reporting under 12 CFR
225.4(f).
4. Expanding on the discussion in the
Preliminary Statement, explain how Applicants and the
resultant institution would assist in meeting the
convenience and needs of the communities to be served by
the proposed transaction. Include in your discussion how
Applicants define the “communities to be served by the
proposed transaction.â€
5. Applicants indicate plans to
submit a Community Reinvestment Act (“CRAâ€) Strategic Plan
to the Office of the Comptroller of the Currency (“OCCâ€)
at a later date. Provide an anticipated timeframe for such
submission.
6. Applicants indicate they will define a
primary Assessment Area of the Bridgeport-
Stamford-Norwalk-Danbury, Connecticut metropolitan
statistical area and establish a broader Assessment
Area reflecting Revolut Bank’s nationwide operating model.
Discuss the criteria and process Applicants plan to use to
establish a broader Assessment Area and what that broader
Assessment Area will be, if known.
7. OCC regulations require a bank to
solicit views from the public on proposed Strategic Plans
both formally and informally. Discuss, with specificity,
how Applicants plan to meet these requirements. Include in
your discussion a proposed timeline for such
solicitations.
8. Discuss, with specificity, what products
and services Applicants and the resultant institution
would offer that would most benefit low- and moderate-
income consumers and communities. "
Full letter on Patreon here.
On September 2, the OCC belatedly responded to
Inner City Press's FOIA request for records concerning
Revolut's proposed national bank charter — and withheld 89
percent of what it found. Of 1,526 responsive pages, only
121 were released in full; 1,362 were withheld entirely.
What did survive redaction is telling: OCC's own genial
Deputy Comptroller for Chartering confirmed in writing to
the examiner running the file that Revolut's application
is being treated internally as "Novel" — the OCC's own
category for charter applications presenting genuinely new
business models requiring heightened review.
Inner City Press has appealed, arguing that
if material this specific and non-sensitive survived
disclosure in the small slice of pages OCC did release,
the agency's near-total withholding of the rest is
difficult to credit as properly segregated rather than
simply withheld wholesale. Watch this site.
Watch this site.
