At this time, Revolut is still an EMI or it has acquired some bank license? They were promising a long time to be a bank...
By the way, in terms of tax compliance or AML, I'm right saying that is so much riskier to hold money on an EMI than in a bank account? I assume that EMI's can block you for any little s**t they want, but N26, Bunq, etc...being real banks would not be that rude neither block your account if there isn't something very bad or judge prosecuting you
There is still a risk and that's why you want to split all your money into several EMI's and banks. You never put all your eggs in one basked as a good saying says.
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Lithuania is the only EU/EEA country to have enacted the special banking license regulation permitted under the applicable EU directive. Instead of the normal 5 million EUR paid up capital requirement, this license only requires 2 million EUR.
They like to call a banking license but it might be worth noting that it's not a full banking license the way people in the EU are used to. The difference is probably insignificant, though, as the only significant deviation from traditional banking licenses is just that this license doesn't allow Revolut to run pension schemes and certain investment products.
However, due to apparent ties with Russia, ECB has pressured Bank of Lithuania to re-review the license for Revolut. It's unclear what will happen. It would be embarrassing for Lithuania to revoke the license and could chill investors' attitudes to Lithuania which are currently very warm. On the other hand, it would be terrible for Lithuania to have issued a banking license to Revolut if it turns out to be another Russian laundromat.
Revolut recently went out and said they will launch their banking product this year as well as launch in US. It wouldn't be the first time they fail to do so, though.