
I was going to change this, but am reposting a LinkedIn update from Leonid Bashlykov, who heads up Crypto at Revolut because it further clarifies the blog I posted last week. The post was titled: Launch a bank from your bedroom which, unsurprisingly, gained a lot of criticism from good luck with that to wait till the regulator finds out. Yea … so Leonid just posted that Anyone can launch a Neobank. How? Here’s the fundamental 3-step playbook:
1️⃣ Wallet infra
Start with an out-of-the box non-custodial wallet — Privy, Turnkey, Portal — as the foundation. Security and user trust from day one.
2️⃣ Payment rails & compliance
⚡ Stablecoin ↔ Fiat rails — plug in Bridge, Due, OpenPayd for global on/off-ramps (+ consider decentralised p2p in underserved markets e.g. Anzo Labs)
💳 Cards / Pmts — issue cards via Gnosis Pay, Striga, Kulipa; add local pmt options where needed (e.g. UPI, Pix)
👤 KYC — integrate Onfido, Sumsub, Trulioo to stay compliant
3️⃣ Sleek UX layer
Build a Revolut-style experience with Lovable, Flutter Dev, React Native. MVP in days instead of months (a lot of refactoring after tho).
Core flows to nail:
💳 Virtual accounts (USD, EUR, ...) — stable, globally accepted ccys
🪪 Card issuance (Visa/Mastercard) — simplest way to spend anywhere
💸 Local & intnl payments — p2p, cross-border, QR pmts
💰 Savings — connect Morpho to enable native yield on stables
🔄 Real-time FX — cut intermediaries, minimise fees
📋 Transaction history — simple money movement tracker
Oh my, the world has changed.
Funnily enough Leonid does caveat his post that the above is a huge simplification but purely “shows how much easier it has become to build a banking app today”. In other words, the regulators are still there, waiting in the wings, to make it all a lot more difficult.
Revolut still doesn’t have its full UK banking licence. What’s going on?
The main issue is for Revolut is that it wants to launch full banking with credit cards, mortgages and loans – as that’s where the profit lies – but, with ten million UK customers already, they have to reposition the whole company to adapt from being a travelcard to a fully licensed bank, and that takes time. After seeing Monzo do this, it actually means re-onboarding every single one of those customers who want a full bank service, as you have to have all of that KYC (Know Your Customer) compliance stuff on file.
This is why any firm moving from payments and prepaid cards has to go through a mobilisation period to become a fully-fledged bank. This can take a while - Zopa took 18 months to move from a loan firm to a bank - and it requires having all the internal controls, mechanisms, processes and people in place from day one to be a fully-fledged bank.
Add to this that there are political manoeuvres as part of the licensing process with questions over compliance controls in the example of Revolut. An October BBC Panorama report identified the company as having the most fraud cases of any bank in Britain.
Equally, Revolut’s mobilisation process is highly political. At the tail end of July, the FT reported that the UK Chancellor, Rachel Reeves, brokered a three-way meeting between Treasury officials, BoE regulators and Revolut to discuss the issue ... which was then personally blocked by the Governor of the Bank of England (the central bank), Andrew Bailey. Bailey later denied a “falling out” with the UK government over delays to the fintech giant’s banking licence, but the damage was done.
So, you can see that it is nowhere near as simple as just launching an app from your bedroom to become a fully-fledged bank.

Chris M Skinner
Chris Skinner is best known as an independent commentator on the financial markets through his blog, TheFinanser.com, as author of the bestselling book Digital Bank, and Chair of the European networking forum the Financial Services Club. He has been voted one of the most influential people in banking by The Financial Brand (as well as one of the best blogs), a FinTech Titan (Next Bank), one of the Fintech Leaders you need to follow (City AM, Deluxe and Jax Finance), as well as one of the Top 40 most influential people in financial technology by the Wall Street Journal's Financial News. To learn more click here...