Brazil’s Nubank Secures OCC Conditional Approval for U.S. National Bank – Potential Crypto Custody Ahead?

By: crypto insight|2026/02/02 00:00:00
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Key Takeaways

  • Nubank has received conditional approval from the U.S. OCC to establish a national bank, with potential for future crypto custody services.
  • The fintech giant aims to blend traditional banking with cryptocurrency services, leveraging a unified federal license.
  • As Nubank expands into the U.S., it signals a significant shift toward incorporating digital asset management under the federal banking system.
  • Nubank’s growth strategy exemplifies how a digital-first banking model thrives in a regulated environment amidst increasing competition.

WEEX Crypto News, 2026-02-01 14:12:35

In a landmark move, Brazil’s leading financial technology firm, Nubank, has attained conditional approval from the U.S. Office of the Comptroller of the Currency (OCC) to establish a national bank. This pivotal approval brings Nubank closer to its ambition of offering regulated crypto custody services within the U.S., an area the fintech company has keenly eyed as part of an expansive growth strategy. This opportunity comes approximately 121 days following Nubank’s initial application on September 30, 2025, signaling the firm’s relentless drive to integrate into the U.S. financial landscape.

A New Horizon for Nubank: Integration of Banking and Crypto Services

With this conditional approval, Nubank can officially proceed with forming a federally-regulated financial entity, known as Nubank, N.A. Upon full approval, this national bank charter will enable Nubank to offer a range of consumer banking products, including deposit accounts, credit card services, and lending options. Most notably, it will include the custody of digital assets, marking a significant evolution as traditional banking services merge with digital asset management.

In contrast to traditional trust charters—which often limit financial institutions to collecting deposits and making loans—the national bank charter promises Nubank a more comprehensive operational capacity. This ability to blend conventional banking services with the relatively newer crypto custody offerings is a pioneering step in the banking sector.

The CEO and founder of Nubank, David Vélez, envisions this approval as evidence that digital-first banking models are not only viable but can thrive on a global scale, reinforcing their appeal in highly-regulated settings. This strategy aligns with Nubank’s overall mission to reshape the future of banking through innovation and adaptability.

Cristina Junqueira, a co-founder of Nubank, will be spearheading the U.S. operations, adding her strategic insight and leadership to the American market. She will have the support of Roberto Campos Neto, the former President of Brazil’s Central Bank, who assumes the role of board chairman in this new venture.

Established in São Paulo in 2013, Nubank has grown from its roots in Brazil to become a global heavyweight in digital financial services, boasting a customer base upward of 127 million across Brazil, Mexico, and Colombia. It is the largest privately held financial organization in Brazil by customer volume, listed publicly on the New York Stock Exchange since 2021 under the ticker NU. As of the third fiscal quarter of 2025, Nubank reported an impressive revenue increase of 39% year over year, hitting the $4.2 billion mark.

Bridging Conventional and Digital Finance

Having laid a formidable foundation in digital finance, Nubank is strategically poised to deepen its foothold within the burgeoning crypto space. From 2022 onwards, Nubank has expanded its crypto-related offerings significantly. A partnership with Paxos enabled the fintech to initially allow users to buy, sell, and store cryptocurrencies directly within its app. Nubank has also been exploring stablecoin transactions linked to credit cards, reflecting a keen interest in integrating these digital currencies into mainstream financial activities.

The decision to incorporate stablecoins, starting with credit card transaction integration, further exemplifies Nubank’s innovative approach to harmonizing traditional finance and digital currencies. As a testament to these efforts, Nubank’s crypto products have rapidly evolved, encompassing multiple tokens, facilitating on-chain transfers to external wallets, enabling in-app exchanges, and supporting yield-generating mechanisms on stablecoins.

By August 2025, Nubank proudly declared a user base of over 6.6 million crypto enthusiasts, primarily consisting of millennials and Gen Z consumers. This demographic notably aligns with the growing trend of younger generations engaging more deeply with digital currencies.

The Regulatory Landscape and Nubank’s Strategic Inroads

The conditional approval by the OCC is part of a more extensive regulatory movement in Washington to integrate digital asset activities into the federal banking infrastructure. This strategic consideration by Nubank reflects a well-timed response to the shifting regulatory dynamics and an expanding market for crypto-based financial services.

In December 2025, the OCC extended conditional approval to several other crypto-native firms, including Circle, Ripple, BitGo, Fidelity Digital Assets, and Paxos. These firms were authorized to operate national trust banks primarily focusing on custody and fiduciary services. This move is indicative of the federal regulator’s gradual but deliberate attempts to regulate the digital asset sphere under a robust legal framework.

Early 2026 saw an uptick in applications from entities like Laser Digital, backed by Nomura, and World Liberty Financial, a Trump-affiliated firm, reflecting the growing interest from diverse segments to secure a foothold in the U.S. market’s regulated crypto space. Additionally, Revolut has hinted at rekindling its ambition for a U.S. banking license after previously dropping an acquisition strategy. These developments indicate a broad recognition of the potential symbiosis between regulated banking and digital asset services.

Nubank’s Brand Alignment and Growth Vision

At the core of Nubank’s expansion strategy is a commitment to aligning business goals with regulatory compliance and customer trust. By securing a national bank charter with the capacity to offer crypto custody, Nubank positions itself as a beacon of innovation in the wider financial sector. This alignment not only fortifies its brand as a reliable fintech leader but also ensures it remains competitive in a rapidly evolving industry.

Nubank’s pursuit of a unified federal banking license enabling both traditional banking and crypto services under a single umbrella underscores its forward-thinking approach. The fintech’s strategic alignment with regulatory standards paves the way for a seamless integration of new-age digital forms of money with established financial systems.

The Challenges and Opportunities Ahead

While Nubank’s regulatory approval marks a significant milestone, it also signals challenges and opportunities that lie ahead. The journey from conditional approval to full-scale operational status demands stringent adherence to regulatory mandates, extensive capital investment, and strategic market positioning. Nubank has been granted a generous 12 months to capitalize thoroughly and an additional 18 months to fully launch the bank, presenting a timeline that requires meticulous planning and execution.

Furthermore, integrating crypto custody and other digital asset services within the banking framework must address concerns of security, consumer protection, and systemic risk management. Nubank’s ability to navigate these complexities will be indicative of its resilience and adaptability in fostering trust and satisfaction among its customers.

As Nubank embarks on this progressive path, its strategy might serve as a benchmark for other fintech firms aspiring to make similar transitions. This path highlights the significance of pursuing innovative product offerings while remaining grounded in regulatory compliance and customer-centric service delivery.

Conclusion: Paving The Way for a New Banking Era

Nubank’s advancement into the U.S. financial landscape with a national bank charter geared towards crypto services sets the stage for new possibilities in the banking industry. As traditional banking intersects with digital currency solutions, Nubank’s strategy could transform financial services accessibility, delivering enhanced value to customers who stand at the convergence of these spheres.

With robust leadership in place, strategic foresight, and an unwavering commitment to innovation, Nubank is likely to not only meet but exceed expectations in integrating comprehensive digital and traditional banking services. This seminal moment for Nubank might very well herald a new era for fintech firms aiming to balance regulatory depth with technological breadth.

Frequently Asked Questions (FAQ)

What does Nubank’s OCC conditional approval mean?

Nubank’s conditional approval by the OCC allows the fintech to establish a national bank in the U.S., potentially paving the way for regulated crypto custody services. It marks an important step in integrating traditional banking with digital currency solutions.

How does Nubank plan to integrate crypto services?

Nubank plans to offer a full suite of consumer banking products, including digital asset custody. By partnering initially with Paxos and experimenting with stablecoin payments, Nubank has laid the groundwork for further expansion into the crypto space.

What challenges might Nubank face?

Nubank must adhere to strict regulatory requirements, secure extensive capital investment, and ensure the seamless implementation of integrated banking and crypto services. Balancing innovation with compliance will be crucial to its success.

How does Nubank’s growth strategy align with regulatory trends?

Nubank’s growth strategy exemplifies a digital-first approach aligned with increasing regulatory oversight of digital assets in the U.S. Its pursuit of a national bank charter reflects its readiness to operate within a structured regulatory framework.

What impact could this approval have on the fintech industry?

Nubank’s approval could serve as a model for other fintech companies seeking to combine traditional banking with innovative digital asset services. This could lead to the broader acceptance of crypto within mainstream financial systems, revolutionizing industry practices.

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China's Central Bank and Eight Other Departments' Latest Regulatory Focus: Key Attention to RWA Tokenized Asset Risk


Foreword: Today, the People's Bank of China's website published the "Notice of the People's Bank of China, National Development and Reform Commission, Ministry of Industry and Information Technology, Ministry of Public Security, State Administration for Market Regulation, China Banking and Insurance Regulatory Commission, China Securities Regulatory Commission, State Administration of Foreign Exchange on Further Preventing and Dealing with Risks Related to Virtual Currency and Others (Yinfa [2026] No. 42)", the latest regulatory requirements from the eight departments including the central bank, which are basically consistent with the regulatory requirements of recent years. The main focus of the regulation is on speculative activities such as virtual currency trading, exchanges, ICOs, overseas platform services, and this time, regulatory oversight of RWA has been added, explicitly prohibiting RWA tokenization, stablecoins (especially those pegged to the RMB). The following is the full text:


To the people's governments of all provinces, autonomous regions, and municipalities directly under the Central Government, the Xinjiang Production and Construction Corps:


  Recently, there have been speculative activities related to virtual currency and Real-World Assets (RWA) tokenization, disrupting the economic and financial order and jeopardizing the property security of the people. In order to further prevent and address the risks related to virtual currency and Real-World Assets tokenization, effectively safeguard national security and social stability, in accordance with the "Law of the People's Republic of China on the People's Bank of China," "Law of the People's Republic of China on Commercial Banks," "Securities Law of the People's Republic of China," "Law of the People's Republic of China on Securities Investment Funds," "Law of the People's Republic of China on Futures and Derivatives," "Cybersecurity Law of the People's Republic of China," "Regulations of the People's Republic of China on the Administration of Renminbi," "Regulations on Prevention and Disposal of Illegal Fundraising," "Regulations of the People's Republic of China on Foreign Exchange Administration," "Telecommunications Regulations of the People's Republic of China," and other provisions, after reaching consensus with the Cyberspace Administration of China, the Supreme People's Court, and the Supreme People's Procuratorate, and with the approval of the State Council, the relevant matters are notified as follows:


  I. Clarify the essential attributes of virtual currency, Real-World Assets tokenization, and related business activities


  (I) Virtual currency does not possess the legal status equivalent to fiat currency. Virtual currencies such as Bitcoin, Ether, Tether, etc., have the main characteristics of being issued by non-monetary authorities, using encryption technology and distributed ledger or similar technology, existing in digital form, etc. They do not have legal tender status, should not and cannot be circulated and used as currency in the market.


  The business activities related to virtual currency are classified as illegal financial activities. The exchange of fiat currency and virtual currency within the territory, exchange of virtual currencies, acting as a central counterparty in buying and selling virtual currencies, providing information intermediary and pricing services for virtual currency transactions, token issuance financing, and trading of virtual currency-related financial products, etc., fall under illegal financial activities, such as suspected illegal issuance of token vouchers, unauthorized public issuance of securities, illegal operation of securities and futures business, illegal fundraising, etc., are strictly prohibited across the board and resolutely banned in accordance with the law. Overseas entities and individuals are not allowed to provide virtual currency-related services to domestic entities in any form.


  A stablecoin pegged to a fiat currency indirectly fulfills some functions of the fiat currency in circulation. Without the consent of relevant authorities in accordance with the law and regulations, any domestic or foreign entity or individual is not allowed to issue a RMB-pegged stablecoin overseas.


(II)Tokenization of Real-World Assets refers to the use of encryption technology and distributed ledger or similar technologies to transform ownership rights, income rights, etc., of assets into tokens (tokens) or other interests or bond certificates with token (token) characteristics, and carry out issuance and trading activities.


  Engaging in the tokenization of real-world assets domestically, as well as providing related intermediary, information technology services, etc., which are suspected of illegal issuance of token vouchers, unauthorized public offering of securities, illegal operation of securities and futures business, illegal fundraising, and other illegal financial activities, shall be prohibited; except for relevant business activities carried out with the approval of the competent authorities in accordance with the law and regulations and relying on specific financial infrastructures. Overseas entities and individuals are not allowed to illegally provide services related to the tokenization of real-world assets to domestic entities in any form.


  II. Sound Work Mechanism


  (III) Inter-agency Coordination. The People's Bank of China, together with the National Development and Reform Commission, the Ministry of Industry and Information Technology, the Ministry of Public Security, the State Administration for Market Regulation, the China Banking and Insurance Regulatory Commission, the China Securities Regulatory Commission, the State Administration of Foreign Exchange, and other departments, will improve the work mechanism, strengthen coordination with the Cyberspace Administration of China, the Supreme People's Court, and the Supreme People's Procuratorate, coordinate efforts, and overall guide regions to carry out risk prevention and disposal of virtual currency-related illegal financial activities.


  The China Securities Regulatory Commission, together with the National Development and Reform Commission, the Ministry of Industry and Information Technology, the Ministry of Public Security, the People's Bank of China, the State Administration for Market Regulation, the China Banking and Insurance Regulatory Commission, the State Administration of Foreign Exchange, and other departments, will improve the work mechanism, strengthen coordination with the Cyberspace Administration of China, the Supreme People's Court, and the Supreme People's Procuratorate, coordinate efforts, and overall guide regions to carry out risk prevention and disposal of illegal financial activities related to the tokenization of real-world assets.


  (IV) Strengthening Local Implementation. The people's governments at the provincial level are overall responsible for the prevention and disposal of risks related to virtual currencies and the tokenization of real-world assets in their respective administrative regions. The specific leading department is the local financial regulatory department, with participation from branches and dispatched institutions of the State Council's financial regulatory department, telecommunications regulators, public security, market supervision, and other departments, in coordination with cyberspace departments, courts, and procuratorates, to improve the normalization of the work mechanism, effectively connect with the relevant work mechanisms of central departments, form a cooperative and coordinated working pattern between central and local governments, effectively prevent and properly handle risks related to virtual currencies and the tokenization of real-world assets, and maintain economic and financial order and social stability.


  III. Strengthened Risk Monitoring, Prevention, and Disposal


  (5) Enhanced Risk Monitoring. The People's Bank of China, China Securities Regulatory Commission, National Development and Reform Commission, Ministry of Industry and Information Technology, Ministry of Public Security, State Administration of Foreign Exchange, Cyberspace Administration of China, and other departments continue to improve monitoring techniques and system support, enhance cross-departmental data analysis and sharing, establish sound information sharing and cross-validation mechanisms, promptly grasp the risk situation of activities related to virtual currency and real-world asset tokenization. Local governments at all levels give full play to the role of local monitoring and early warning mechanisms. Local financial regulatory authorities, together with branches and agencies of the State Council's financial regulatory authorities, as well as departments of cyberspace and public security, ensure effective connection between online monitoring, offline investigation, and fund tracking, efficiently and accurately identify activities related to virtual currency and real-world asset tokenization, promptly share risk information, improve early warning information dissemination, verification, and rapid response mechanisms.


  (6) Strengthened Oversight of Financial Institutions, Intermediaries, and Technology Service Providers. Financial institutions (including non-bank payment institutions) are prohibited from providing account opening, fund transfer, and clearing services for virtual currency-related business activities, issuing and selling financial products related to virtual currency, including virtual currency and related financial products in the scope of collateral, conducting insurance business related to virtual currency, or including virtual currency in the scope of insurance liability. Financial institutions (including non-bank payment institutions) are prohibited from providing custody, clearing, and settlement services for unauthorized real-world asset tokenization-related business and related financial products. Relevant intermediary institutions and information technology service providers are prohibited from providing intermediary, technical, or other services for unauthorized real-world asset tokenization-related businesses and related financial products.


  (7) Enhanced Management of Internet Information Content and Access. Internet enterprises are prohibited from providing online business venues, commercial displays, marketing, advertising, or paid traffic diversion services for virtual currency and real-world asset tokenization-related business activities. Upon discovering clues of illegal activities, they should promptly report to relevant departments and provide technical support and assistance for related investigations and inquiries. Based on the clues transferred by the financial regulatory authorities, the cyberspace administration, telecommunications authorities, and public security departments should promptly close and deal with websites, mobile applications (including mini-programs), and public accounts engaged in virtual currency and real-world asset tokenization-related business activities in accordance with the law.


  (8) Strengthened Entity Registration and Advertisement Management. Market supervision departments strengthen entity registration and management, and enterprise and individual business registrations must not contain terms such as "virtual currency," "virtual asset," "cryptocurrency," "crypto asset," "stablecoin," "real-world asset tokenization," or "RWA" in their names or business scopes. Market supervision departments, together with financial regulatory authorities, legally enhance the supervision of advertisements related to virtual currency and real-world asset tokenization, promptly investigating and handling relevant illegal advertisements.


  (IX) Continued Rectification of Virtual Currency Mining Activities. The National Development and Reform Commission, together with relevant departments, strictly controls virtual currency mining activities, continuously promotes the rectification of virtual currency mining activities. The people's governments of various provinces take overall responsibility for the rectification of "mining" within their respective administrative regions. In accordance with the requirements of the National Development and Reform Commission and other departments in the "Notice on the Rectification of Virtual Currency Mining Activities" (NDRC Energy-saving Building [2021] No. 1283) and the provisions of the "Guidance Catalog for Industrial Structure Adjustment (2024 Edition)," a comprehensive review, investigation, and closure of existing virtual currency mining projects are conducted, new mining projects are strictly prohibited, and mining machine production enterprises are strictly prohibited from providing mining machine sales and other services within the country.


  (X) Severe Crackdown on Related Illegal Financial Activities. Upon discovering clues to illegal financial activities related to virtual currency and the tokenization of real-world assets, local financial regulatory authorities, branches of the State Council's financial regulatory authorities, and other relevant departments promptly investigate, determine, and properly handle the issues in accordance with the law, and seriously hold the relevant entities and individuals legally responsible. Those suspected of crimes are transferred to the judicial authorities for processing according to the law.


 (XI) Severe Crackdown on Related Illegal and Criminal Activities. The Ministry of Public Security, the People's Bank of China, the State Administration for Market Regulation, the China Banking and Insurance Regulatory Commission, the China Securities Regulatory Commission, as well as judicial and procuratorial organs, in accordance with their respective responsibilities, rigorously crack down on illegal and criminal activities related to virtual currency, the tokenization of real-world assets, such as fraud, money laundering, illegal business operations, pyramid schemes, illegal fundraising, and other illegal and criminal activities carried out under the guise of virtual currency, the tokenization of real-world assets, etc.


  (XII) Strengthen Industry Self-discipline. Relevant industry associations should enhance membership management and policy advocacy, based on their own responsibilities, advocate and urge member units to resist illegal financial activities related to virtual currency and the tokenization of real-world assets. Member units that violate regulatory policies and industry self-discipline rules are to be disciplined in accordance with relevant self-regulatory management regulations. By leveraging various industry infrastructure, conduct risk monitoring related to virtual currency, the tokenization of real-world assets, and promptly transfer issue clues to relevant departments.


  IV. Strict Supervision of Domestic Entities Engaging in Overseas Business Activities


(XIII) Without the approval of relevant departments in accordance with the law and regulations, domestic entities and foreign entities controlled by them may not issue virtual currency overseas.


  (XIV) Domestic entities engaging directly or indirectly in overseas external debt-based tokenization of real-world assets, or conducting asset securitization activities abroad based on domestic ownership rights, income rights, etc. (hereinafter referred to as domestic equity), should be strictly regulated in accordance with the principles of "same business, same risk, same rules." The National Development and Reform Commission, the China Securities Regulatory Commission, the State Administration of Foreign Exchange, and other relevant departments regulate it according to their respective responsibilities. For other forms of overseas real-world asset tokenization activities based on domestic equity by domestic entities, the China Securities Regulatory Commission, together with relevant departments, supervise according to their division of responsibilities. Without the consent and filing of relevant departments, no unit or individual may engage in the above-mentioned business.


  (15) Overseas subsidiaries and branches of domestic financial institutions providing Real World Asset Tokenization-related services overseas shall do so legally and prudently. They shall have professional personnel and systems in place to effectively mitigate business risks, strictly implement customer onboarding, suitability management, anti-money laundering requirements, and incorporate them into the domestic financial institutions' compliance and risk management system. Intermediaries and information technology service providers offering Real World Asset Tokenization services abroad based on domestic equity or conducting Real World Asset Tokenization business in the form of overseas debt for domestic entities directly or indirectly venturing abroad must strictly comply with relevant laws and regulations. They should establish and improve relevant compliance and internal control systems in accordance with relevant normative requirements, strengthen business and risk control, and report the business developments to the relevant regulatory authorities for approval or filing.


  V. Strengthen Organizational Implementation


  (16) Strengthen organizational leadership and overall coordination. All departments and regions should attach great importance to the prevention of risks related to virtual currencies and Real World Asset Tokenization, strengthen organizational leadership, clarify work responsibilities, form a long-term effective working mechanism with centralized coordination, local implementation, and shared responsibilities, maintain high pressure, dynamically monitor risks, effectively prevent and mitigate risks in an orderly and efficient manner, legally protect the property security of the people, and make every effort to maintain economic and financial order and social stability.


  (17) Widely carry out publicity and education. All departments, regions, and industry associations should make full use of various media and other communication channels to disseminate information through legal and policy interpretation, analysis of typical cases, and education on investment risks, etc. They should promote the illegality and harm of virtual currencies and Real World Asset Tokenization-related businesses and their manifestations, fully alert to potential risks and hidden dangers, and enhance public awareness and identification capabilities for risk prevention.


  VI. Legal Responsibility


  (18) Engaging in illegal financial activities related to virtual currencies and Real World Asset Tokenization in violation of this notice, as well as providing services for virtual currencies and Real World Asset Tokenization-related businesses, shall be punished in accordance with relevant regulations. If it constitutes a crime, criminal liability shall be pursued according to the law. For domestic entities and individuals who knowingly or should have known that overseas entities illegally provided virtual currency or Real World Asset Tokenization-related services to domestic entities and still assisted them, relevant responsibilities shall be pursued according to the law. If it constitutes a crime, criminal liability shall be pursued according to the law.


  (19) If any unit or individual invests in virtual currencies, Real World Asset Tokens, and related financial products against public order and good customs, the relevant civil legal actions shall be invalid, and any resulting losses shall be borne by them. If there are suspicions of disrupting financial order and jeopardizing financial security, the relevant departments shall deal with them according to the law.


  This notice shall enter into force upon the date of its issuance. The People's Bank of China and ten other departments' "Notice on Further Preventing and Dealing with the Risks of Virtual Currency Trading Speculation" (Yinfa [2021] No. 237) is hereby repealed.


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