Others have taken quieter routes into the market. Banco Inter acquired USEND in 2021 and initially operated under a money transmitter licence before later securing a banking branch licence. OakNorth built exposure by lending to US businesses from its UK entity before acquiring a Michigan community bank.

Two different theories of digital banking expansion are now playing out. The first is local specialisation: win deeply at home and avoid markets where customer acquisition, compliance, and product localisation costs are too high. For Monzo and N26, Europe offers a clearer near-term path to scale, especially with passporting across the region.

The second is global expansion from a position of strength. Nubank, Revolut, and bunq are entering or re-entering the US with stronger balance sheets, larger customer bases, and more mature operating models. Nubank’s US entry, in particular, comes after reaching significant scale and profitability in Latin America.

The challenge remains structural. A European banking licence can passport across multiple countries, while a US charter still requires navigating federal regulators, state-level frameworks, and a highly competitive consumer banking market. The revenue model is also different. European neobanks grew heavily on interchange, while US banking economics depend more on lending, deposits, and product depth.

What has changed is the regulatory moment. The OCC appears more open to new charter applications, with a rise in filings since early 2025 and faster approvals for some applicants.