By Doing Business International | October 7, 2025
The question is no longer simply who files first. The real inquiry is: who can prove governance maturity, compliance-by-design, and transparent consumer value, fast enough to sustain growth?
Here’s why, in 2025, the U.S. banking license is suddenly the coveted trophy:
1. Resilient distribution
Having the ability to offer insured deposit accounts gives a firm stable, low-cost funding and a direct customer relationship. It reduces reliance on partners and makes “stickiness” more credible.
2. Full-stack economics
Once you control deposits, you can lend, you earn interest margins; you can issue cards and capture interchange; you can bundle more services and cross-sell.
3. Institutional credibility
For fintechs and crypto players alike, operating inside a recognized banking or trust charter gives institutional counterparties confidence. It smooths partnerships with corporate clients, banks, and capital markets.
4. Policy tailwinds, or headwinds
If regulators accelerate approval, challengers will flood in. If they tighten the gate, Banking as a Service (BaaS) remains the fallback, but with thinner margins and dependency risk.
In short: firms without a license can build interesting businesses, but their scalability may always be under external constraint.
In a landmark move, Nubank formally applied for a U.S. national bank charter in September 2025. The Brazilian fintech, already serving over 120 million customers across Brazil, Mexico, and Colombia, sees this as a bridge from regional dominance to global scale.
What makes Nubank’s approach compelling is how it marries cultural identity with regulated capability:
• Start with Latinos: Many prospective U.S. customers are underbanked or thin-file, not well served by incumbent banks. Nubank’s diaspora credibility gives it a wedge of trust and lower CAC (customer acquisition cost).
• Underwriting finesse: They already work in credit-thin, informally documented markets; that experience may translate into better underwriting models for unbanked and “thin file” U.S. customers.
• Card-led growth + transparency: Nubank’s ethos has long emphasized fairness and simplicity. That plays well in U.S. markets now fatigued by opaque fees and surprises.
• Optionality in cross-sell: Once deposits and credit work, the path opens to savings, small business lending, maybe even crypto/digital-asset features (if permitted and carefully controlled).
If the charter is granted, expect a playbook oriented around localized entry, then national scale, with compliance posture as a visible anchor to regulators.
There is risk: turning a “Latin American neobank” into a U.S. national bank is heavy lifting, not just product translation, but governance, capital structure, stress planning, board oversight, and audit readiness.
Across the Atlantic, Monzo is reportedly preparing a renewed push for a U.S. banking license, four years after abandoning an earlier attempt. The difference this time: the regulatory environment and Monzo’s institutional maturity may align better.
In its prior attempt (circa 2021), Monzo faced discouraging signals from the OCC and regulatory ambiguity, and it eventually withdrew. Now, with U.S. regulators dialing back some regulatory barriers and guidance, Monzo believes the odds of approval may be improved.
Monzo’s strengths are clear: a beloved consumer UX, sticky features like “Savings Jars,” and brand affinity among tech-savvy users. The challenge is proving to U.S. regulators that Monzo has matured the governance, capital planning, and compliance layers necessary in a banking charter.
There are two possible scenarios:
• Fast approvals: If Monzo succeeds, it catalyzes a wave of new challengers in U.S. deposits and everyday banking.
• Slow, status quo path: If approvals stay sluggish, Monzo must rely on BaaS partnerships (as many foreign challengers do today), which is viable but margin-constrained.
The winners will combine delightful consumer experience with heavyweight regulatory discipline.
In October 2025, Coinbase announced it is seeking a National Trust Company Charter under the Office of the Comptroller of the Currency (OCC). This is not equivalent to becoming a full bank with broad deposit-taking, but it could professionalize its custody, payments, and institutional rails within a stricter trust legal environment.
In Coinbase’s words, the move is meant to strengthen regulatory oversight and bridge the gap between crypto and traditional finance.
Here’s how that might change things in practice:
• Custody hardening: Segregation of client assets, more robust controls, frequent audits, independent attestations.
• Payment rails and settlement clarity: If Coinbase can operate closer to core rails, settlement becomes more reliable and counterparty risk more transparent.
• Institutional on-ramps: Enterprises that today balk at crypto integration may find it safer to partner with a trust-chartered entity.
Coinbase has emphasized that it does not plan to become a full commercial bank. Still, the move reflects convergence: the overlay of traditional finance disciplines onto crypto infrastructure.
Across these cases, one principle is dominant: trust is the product. In U.S. financial regulation, you don’t buy access, you earn it through operational evidence.
U.S. regulators (OCC, FDIC, Federal Reserve) look for signals that a firm treats compliance, monitoring, reporting, escalation and resilience as first-order design features, not afterthoughts. Some of the tangible signals include:
• Board independence and serious risk oversight
• A well-staffed, empowered second line (compliance, risk, audit) proportional to growth
• AML/KYC frameworks, sanctions screening, fraud detection, privacy rules baked into flows
• Metrics on complaint resolution, fair treatment, reversals or mistakes
• Capital planning, stress testing, liquidity buffers tied to real portfolios
• Transparent reporting and (ideally) third-party audits or assurance
• What tilts in practice isn’t branding or speed, but operational maturity.
For global fintechs today, two broad strategic routes remain:
1. Charter (or trust charter)
Pros: control, margins, durability, autonomy.
Cons: slower, higher regulatory burden, capital cost, complexity.
2. Banking as a Service (BaaS)
Pros: faster market entry, leaner initial capital, flexibility.
Cons: margin compression, dependency on partners, limited control.
Many firms will hybridize: start via BaaS to test product-market fit, then migrate to a charter once scale and regulatory posture allow. But doing this mid-flight is risky, core systems, customer communication, compliance frameworks, and operations often need rearchitecting.
The key execution risk: rebuilding under live customers.
If your playbook is to compete in financial services with depth, a few guiding principles emerge:
• Localize deeply
Start with a tight segment (e.g., Latino diaspora, thin-file consumers) before scaling broadly. Tailor underwriting, servicing, experience.
• Engineer compliance
Treat controls and monitoring as product features. The faster you bake compliance into flows, the less brittle your scaling will be.
• Build transparency and credibility
Publish metrics, welcome external auditors, respond to user complaints, close operational loops. Show you are accountable.
• Sequence growth prudently
Don’t chase vanity user numbers before you’ve proven capital, regulatory, and compliance stability. Scale with restraint.
• Design for resilience
Diversify funding sources, maintain liquidity buffers, test continuity plans, and simulate adverse conditions early.
The U.S. charter race is not a land grab. It’s a trust tournament. Nubank’s identity-focused entry, Monzo’s timing-driven return, and Coinbase’s institutionalization of custody all point toward the same destination: durable, regulated rails inside the U.S. financial system.
In that world, the firms that don’t just talk compliance, but turn it into a competitive advantage, are the ones that will win not just approvals, but the right to scale.
Contact our DBi🌐 Experts for more information on Banking, Licenses, Finance and compliance matters, we are ready to help you today!
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