Bunq's Strategic Move for a U.S. Banking License: A Disruptive Force in Cross-Border Banking for Digital Nomads and Expats

The global financial landscape is undergoing a seismic shift as digital nomads and expatriates redefine traditional notions of work and residence. At the forefront of this transformation is bunq, Europe's second-largest neobank, which has recently filed for a U.S. de novo banking license with the Office of the Comptroller of the Currency (OCC). This move, announced in late 2025, signals bunq's intent to directly address the pain points of a growing demographic: location-independent professionals who straddle the U.S. and Europe. For investors, the question is not merely whether bunq can secure regulatory approval but whether its strategy can disrupt a market ripe for innovation.

A Market in Need of Disruption

Digital nomads and expats face systemic challenges in cross-border banking. Traditional institutions often impose high fees, rigid identity verification processes, and limited multi-currency support, creating friction for users who frequently move between jurisdictions. According to a report by JPMorgan, global cross-border payments are projected to grow from $194.6 trillion in 2024 to $320 trillion by 2032, driven by demand for faster, more transparent transactions. Meanwhile, the U.S. alone now hosts 18.5 million digital nomads-12% of its workforce-highlighting a substantial and expanding market.

Current solutions, while improving, remain fragmented. Platforms like Wise (formerly TransferWise) and Revolut offer competitive exchange rates and multi-currency accounts but lack the holistic integration of banking, investment, and localized services that bunq aims to provide. Airwallex, another rival, excels in e-commerce integrations but caters more to entrepreneurs than to the broader expat community. This gap in the market underscores the potential for a platform that combines seamless cross-border functionality with tailored user experiences.

Bunq's Strategic Differentiation

Bunq's application for a U.S. banking license is not an isolated move but part of a broader strategy to become a "transatlantic banking solution." The company has already secured a broker-dealer license in the U.S. and operates in 38 languages, with features such as AI-powered fraud detection and "Travel Mode," which enhances security during international travel. If approved, bunq's U.S. license will enable it to offer dual U.S. and European checking accounts, allowing expats to build credit histories using their European financial records-a critical advantage in markets where traditional banks often exclude newcomers.

The neobank's value proposition extends beyond banking. Its 2025 , which helps nomads compare living costs across cities, exemplifies its commitment to addressing the non-financial needs of its target audience. Additionally, bunq's business account tools, including invoicing and multi-user permissions, cater to the entrepreneurial segment of the nomad community, a niche underserved by competitors.

Regulatory Hurdles and Competitive Challenges

Despite its strengths, bunq faces significant challenges. The U.S. banking regulatory environment is notoriously complex, and the OCC's approval process for de novo licenses is rigorous. The company previously withdrew its 2024 application, citing the need to refine its compliance framework. Investors must weigh the likelihood of regulatory success against the costs of repeated filings and operational delays.

Competition is another wildcard. Revolut and Wise have established brand recognition and user bases, while emerging players like N26 and Chime are expanding their cross-border services. However, bunq's focus on hyper-personalization-such as 3% cashback on transportation expenses and localized customer support-could carve out a unique niche.

Investment Implications

For bunq to succeed, it must execute its U.S. entry with precision. The neobank's 20 million global users represent a foundation for cross-selling, but scaling in the U.S. will require significant capital and marketing. Yet the potential rewards are substantial: a market where traditional banks are ill-equipped to serve a mobile workforce and where cross-border payment growth is outpacing global GDP.

Data from Fintech News suggests that bunq's recent momentum-including its UK EMI license application and FINRA approval-positions it as a serious contender. If the company can navigate regulatory hurdles and differentiate itself through user-centric innovation, it may not only disrupt expat banking but also set a new standard for digital-first financial services in a globalized economy.