Rebaza advises Revolut on banking license in Peru

Rebaza, Alcázar & de las Casas | The Superintendency of Banking, Insurance and AFPs (SBS) has granted the Organization Authorization (Autorización de Organización) to Revolut Bank Perú, by resolution dated March 30, 2026, making it the first 100% digital bank authorized in the Peruvian financial market.

Rebaza, Alcázar & De Las Casas (RAD) acted as sole external counsel to Revolut Group in the process of obtaining the Organization Authorization before the SBS, leading the legal and regulatory strategy in close collaboration with the client’s global and regional teams.

Revolut is a global fintech founded in 2015 in the United Kingdom by Nikolay Storonskiy, recognized for its digital financial services platform and broad international expansion. In Europe, the group operates with a banking license in Lithuania, which allows it to offer banking services within the European Union through its regulated structure in that Member State.

The Organization Authorization constitutes the first stage of the bank licensing process in Peru under the General Law of the Financial System and the Insurance System and Organic Law of the Superintendency of Banking and Insurance (Law 26702). This authorization enables the formal incorporation of the banking entity and represents the necessary step toward the future attainment of the Operating Authorization (Autorización de Funcionamiento) and the commencement of operations.

RAD designed and executed the project’s end-to-end regulatory strategy, including cross-functional coordination with the client’s product, risk, technology, and compliance teams, under Revolut’s executive leadership for the Peruvian market. The advisory work was complemented by international best practices applicable to digital banking models and cross-border operations, in ongoing coordination with the in-house teams.

The client’s international corporate structure supported the local project and facilitated the implementation of a comprehensive digital banking model that prioritizes innovation, technological agility, and the user experience.

The process involved a comprehensive regulatory component that included the design and fitness and propriety assessment of corporate governance, enterprise-wide risk management, information security and cybersecurity, AML/CFT, market conduct, and alignment with prudential standards and financial consumer protection. In parallel, coordination was maintained with the United Kingdom’s Prudential Regulation Authority (PRA), and the favorable opinion of the Central Reserve Bank of Peru (BCRP) was obtained.

This achievement reflects Revolut’s leadership and commitment to a fully regulated operation in Peru, as well as the dedication and integrated work of the RAD team throughout the entire process.

Revolut’s legal advisors:
In?house counsel: Augusto Cáceres – Legal Manager (Peru); Luisa Machado Leite Soares – Regional Head of Legal South America (Brazil); Scott Bickerton – Lead Legal Counsel (United Kingdom); Nikoletta Zinonos – Senior Legal Counsel (United Kingdom).
Rebaza, Alcázar & De Las Casas (Lima, Peru): Partner Rafael Alcázar; Partner Alexandra Orbezo; Senior Associate Camila Hernandez; and Associate Paula Portocarrero.