Revolut and OpenReserve Win OCC Preliminary Approval for US Crypto Banks

The US Office of the Comptroller of the Currency has granted preliminary conditional approval for both Revolut and OpenReserve to charter national banks, with digital asset custody and stablecoin issuance sitting at the core of each business plan. The decision, announced on 4 September 2026, marks a significant expansion of the federally chartered banking perimeter into crypto-native territory and creates new accounting, reporting, and AML obligations that finance teams need to anticipate well before these institutions open their doors.

What the OCC Actually Approved

Preliminary conditional approval is not a banking licence. It is the OCC's signal that a proposed institution has cleared an initial threshold of safety, soundness, and community reinvestment review. The two banks cannot accept deposits or conduct any regulated banking activity until they satisfy all preopening requirements and receive the OCC's final sign-off. That process typically involves capitalisation milestones, staffing sign-offs, technology reviews, and BSA/AML programme certifications.

Revolut's Connecticut Charter

Revolut's proposed bank would be domiciled in Connecticut. The stated rationale is straightforward: the firm currently relies on FDIC-insured partner banks to hold customer funds, a model that adds cost and introduces operational dependencies. A proprietary national bank charter would let Revolut hold deposits directly, price services more competitively, and control its own compliance infrastructure. On the digital asset side, the plan includes custody of crypto assets, the use of stablecoins for cross-border payment rails, and the distribution of a Revolut-branded stablecoin issued by a third party rather than Revolut itself.

OpenReserve's Utah Charter

OpenReserve, founded in 2025 by MoneyLion's former CEO Dee Choubey and backed by Andreessen Horowitz, is building what it describes as a blockchain-native bank. Its Utah charter application centres on tokenized deposits alongside conventional banking services, plus a planned subsidiary that would issue US dollar-backed stablecoins. That subsidiary has not yet filed its own application with the OCC, so it represents a second regulatory hurdle the firm will need to clear separately.

Why This Matters for Accounting and Compliance Teams

Two federally chartered banks with active crypto and stablecoin programmes are a different counterparty risk profile from the state-chartered or money-transmitter-licensed fintechs that most treasury and compliance functions currently deal with. The accounting and AML implications run in several directions simultaneously.

Stablecoin Classification Under GAAP

Stablecoins held or received through a nationally chartered bank sit in an ambiguous category under current US GAAP. The FASB has proposed treating certain stablecoins as cash equivalents when they are redeemable on demand at a fixed amount, but that guidance is still in proposal stage. For a corporate treasury receiving Revolut-branded stablecoins as payment, or holding tokenized deposits at OpenReserve, the classification question is live right now. Is it cash, a cash equivalent, a financial instrument, or an intangible digital asset under ASC 350-60? The answer affects the balance sheet line, the measurement basis, and the disclosure required under ASC 820. Teams relying on stablecoin accounting under FASB's proposed GAAP improvements should flag this development to their auditors immediately, because the counterparty being a national bank does not automatically resolve the classification question.

Digital Asset Custody: On-Balance-Sheet or Off?

Both Revolut and OpenReserve plan to offer digital asset custody. When a firm holds crypto with a nationally chartered custodian, the accounting treatment depends on whether the arrangement constitutes a safekeeping arrangement, a bailment, or a creditor relationship. The SEC's Staff Accounting Bulletin 121, which requires entities that custody crypto on behalf of others to recognise a corresponding liability, applies to public companies. Private firms and partnerships face a different landscape under GAAP and must assess control carefully. If the custodian holds assets as a principal, the crypto may not appear on the client's own balance sheet at all, but that does not eliminate disclosure obligations.

AML and BSA Obligations for Corporate Clients

National banks are subject to the full Bank Secrecy Act framework, including Customer Due Diligence rules, beneficial ownership requirements, and the obligation to file Suspicious Activity Reports. For corporate clients banking with Revolut or OpenReserve, this means onboarding will be materially more rigorous than with an unchartered crypto exchange. Accounting firms advising business clients on treasury strategy should expect enhanced KYC documentation requests, transaction monitoring alerts triggered by stablecoin or cross-border activity, and potential information requests under 31 USC 5318. Firms that already manage this for traditional banking relationships should apply the same workflows here, because the BSA perimeter now explicitly covers these institutions.

Cross-Border Transfer Reporting

Revolut's use of stablecoins for cross-border transfers introduces FinCEN reporting considerations. Transfers of currency or monetary instruments above certain thresholds require Currency Transaction Reports or, in some cases, FBAR or Form 8938 filings at the individual or entity level. Whether a stablecoin transfer through a national bank triggers the same reporting as a wire transfer is a question that FinCEN has not definitively answered for all scenarios, but the regulatory direction of travel is toward treating stablecoins as monetary instruments when they function as such. Accounting teams should not assume that routing a cross-border payment through a stablecoin rail at a national bank exempts it from reporting.

Tokenized Deposits: A New Instrument for the Chart of Accounts

OpenReserve's tokenized deposit offering deserves particular attention. A tokenized deposit is a blockchain-based representation of a bank deposit, not a separately issued stablecoin. The underlying deposit remains a liability of the bank and is covered by FDIC insurance up to the applicable limit. This is materially different from holding a stablecoin issued by a third party, where the holder's claim is against the issuer, not against a deposit-taking institution. For treasury and accounting purposes, the distinction matters for:

• Balance sheet classification: a tokenized deposit at a national bank is likely cash or a cash equivalent, subject to the same maturity and liquidity tests as a conventional deposit.
• FDIC coverage analysis: standard per-depositor limits apply, but the blockchain delivery mechanism raises questions about how beneficial ownership is established for coverage purposes.
• Counterparty risk disclosure: under ASC 825, significant concentrations of credit risk with a single financial institution must be disclosed, and a blockchain-based deposit does not change that requirement.

The broader policy context is worth tracking too. The G20 framework for digital asset innovation has pushed member jurisdictions toward clear regulatory lanes for tokenized deposits and stablecoins, and the OCC's approvals here are consistent with that direction.

Practical Steps for Accounting Firms and CFOs

These approvals are conditional and final opening is some way off, but the planning horizon for accounting policy changes, vendor due diligence, and AML programme updates is now. Finance teams should take these steps in sequence.

Update Your Counterparty Risk Register

Add Revolut Bank NA and OpenReserve Bank to your watchlist as entities in the preopening phase. Once final approval arrives, they will be reportable financial institutions for concentration disclosure purposes. Track the OCC's preopening milestone announcements so your register is updated before the first transaction, not after.

Review Stablecoin and Digital Asset Accounting Policies

If your firm or any client is likely to receive or hold Revolut-branded stablecoins or OpenReserve tokenized deposits, document your intended accounting treatment now. Engage your auditor on the classification question and note where pending FASB guidance may change the answer. Deploying capable crypto bookkeeping software that can handle multiple asset categories, including stablecoins classified differently from standard crypto assets, will reduce year-end adjustment risk.

Assess AML Programme Coverage

National bank relationships require full BSA/AML coverage on both sides. If your AML programme was designed around exchange or money-service-business counterparties, review whether the new procedures map correctly to a national bank relationship. In particular, check whether your transaction monitoring rules flag stablecoin transfers, cross-border crypto payments, and tokenized deposit movements at appropriate thresholds.

Engage Legal Counsel on FinCEN Reporting Positions

Before routing any material cross-border payment through a stablecoin rail at either institution, obtain a documented legal position on CTR, FBAR, and CMIR applicability. The regulatory position is evolving and the cost of a missed filing is disproportionate to the cost of the advice.

Monitor the OCC Preopening Process

Both institutions must meet capital, management, and BSA/AML programme requirements before opening. The OCC's Comptroller's Licensing Manual sets out what those conditions look like in practice. Accounting firms that advise clients in the banking sector should read the preliminary approval orders when they are published in full, as they will specify conditions that shape the eventual product offering and compliance framework.

Frequently Asked Questions

What does OCC preliminary conditional approval mean in practice?

It means the OCC has reviewed the business plan, capital structure, management team, and community reinvestment commitments at an initial level and found them acceptable to proceed. The institutions cannot open or take deposits until all preopening conditions are satisfied and the OCC issues final approval. Think of it as a conditional green light, not an operating licence.

Are stablecoins held at a nationally chartered bank treated as insured deposits?

Not automatically. A stablecoin issued by a third party and held in custody at a national bank is not a deposit and is not FDIC-insured. A tokenized deposit, by contrast, is a representation of an actual bank deposit and should attract FDIC coverage up to the standard limits, though the precise mechanics of how coverage applies to blockchain-delivered instruments are still being worked through by regulators.

How should a CFO classify a Revolut-branded stablecoin on the balance sheet?

Under current US GAAP, the most defensible treatment for a third-party-issued stablecoin is as an intangible digital asset under ASC 350-60, measured at fair value with gains and losses recognised in net income. If FASB finalises its proposal to treat certain redeemable stablecoins as cash equivalents, that treatment would change. Firms should not anticipate the proposed rule in their financial statements without their auditor's sign-off.

Does routing cross-border payments through a stablecoin rail at a national bank affect FinCEN reporting obligations?

Potentially yes. FinCEN's rules on Currency Transaction Reports, the Bank Secrecy Act's travel rule for wire transfers, and FBAR/Form 8938 requirements all turn on the nature of the instrument and the parties involved. A stablecoin used as a payment rail may be treated as a monetary instrument depending on how the transaction is structured. Legal counsel should provide a documented position before material volumes are processed.

What should accounting firms do now, given that these banks have not yet opened?

Use the preopening window to update accounting policies for stablecoin and tokenized deposit instruments, review AML programme coverage for national bank counterparties in the digital asset space, and brief audit committees on the emerging classification and disclosure questions. Waiting until final approval arrives compresses the timeline unnecessarily. Digital asset accounting software that can distinguish between stablecoin categories and tokenized deposit types will be a practical necessity once these institutions are live.

Source: Cointelegraph