Crypto Banking Relationships: How to Get and Keep Bank Accounts

By Chanté Eliaszadeh

Banking access has long been the single most challenging operational hurdle for cryptocurrency companies. The good news, as of 2026, is that the regulatory environment has shifted decisively. A documented, multi-agency thaw over 2025 and into 2026 dismantled much of the federal machinery behind what the industry called “Operation Chokepoint 2.0.” The harder news is that policy change at the regulators has not erased the operational caution of individual banks. Securing and maintaining banking relationships still requires strategic planning, robust compliance programs, and careful relationship management.

I advise crypto companies through the banking application process, from early-stage startups to established platforms. The difference between companies that successfully obtain banking and those that do not comes down to preparation, positioning, and ongoing compliance discipline.

This guide provides a practical roadmap for crypto companies seeking banking relationships, written from a mid-2026 vantage point and grounded in what actually works in the current environment.

Why Crypto Companies Struggled with Banking

The coordinated federal pressure to debank crypto companies, which the industry dubbed “Operation Chokepoint 2.0,” was real and is now well documented. Beginning in early 2025, the FDIC under Acting Chairman Travis Hill released the underlying record. On February 5, 2025, the FDIC released approximately 175 documents related to its supervision of banks that engaged in, or sought to engage in, crypto-related activities. Those documents included correspondence with the roughly 24 banks that had received supervisory “pause” letters directing them to refrain from expanding crypto activity, building on an earlier release of approximately 25 such letters in January 2025.¹

The 2023 banking disruptions sharpened the problem, but it is worth being precise about what actually happened to the three institutions most associated with that period, because they failed in three different ways:

• Silvergate Bank announced a voluntary wind-down and self-liquidation on March 8, 2023. It was not placed into FDIC receivership, and it repaid its depositors. Silvergate later settled with the Federal Reserve, the SEC, and the California Department of Financial Protection and Innovation for approximately $63 million on July 1, 2024 (a $43 million Federal Reserve penalty and a $20 million California DFPI penalty, with a $50 million SEC penalty offset by those payments), resolving allegations of BSA/AML compliance deficiencies.²
• Silicon Valley Bank failed and was placed into FDIC receivership on March 10, 2023.
• Signature Bank was closed by the New York Department of Financial Services on March 12, 2023.

The crypto-specific fallout was significant: Signature Bank’s roughly $4 billion in crypto-related deposits were explicitly excluded from the Flagstar (New York Community Bancorp) acquisition of Signature’s assets, and customers were instructed to close their Signet digital banking accounts.³ Two of the industry’s most sophisticated crypto-banking platforms disappeared in a matter of days.

The 2025-2026 Regulatory Thaw

The change in posture across the federal banking agencies over 2025 and into 2026 was substantial and is documented in primary sources. The practical upshot is a meaningfully more permissive regulatory framework than existed at the trough of 2023-2024.

• OCC (March 7, 2025). The Office of the Comptroller of the Currency issued Interpretive Letter 1183 and an accompanying news release confirming that national banks and federal savings associations may engage in crypto-asset custody, certain stablecoin activities, and participation in independent node verification networks (distributed ledgers). Critically, the OCC removed the prior condition requiring a “supervisory non-objection” and a demonstration of adequate controls before engaging in these activities, rescinding Interpretive Letter 1179.⁴
• OCC (March 20, 2025). The OCC removed references to “reputation risk” and reputational-risk-based supervision from the Comptroller’s Handbook and instructed examiners to stop examining institutions for it.⁵
• FDIC (March 28, 2025). The FDIC issued FIL-7-2025, rescinding FIL-16-2022 and clarifying that FDIC-supervised institutions may engage in permissible crypto-related activities without seeking prior FDIC approval.⁶
• Federal Reserve (April 24, 2025). The Federal Reserve rescinded SR 22-6 (its advance-notification expectation for crypto activity) and SR 23-8 (its non-objection process for dollar-token activity). Together with the FDIC, the Fed also withdrew from the January 2023 and February 2023 interagency joint statements on crypto-asset risks. (The OCC had already withdrawn from those joint statements on March 7, 2025.)⁷
• Executive Order (August 7, 2025). The President signed “Guaranteeing Fair Banking for All Americans,” directing federal banking regulators to remove “reputation risk” and equivalent concepts that enable politicized or unlawful debanking from their guidance and examination materials within 180 days, and directing the Small Business Administration to identify and help reinstate clients who were improperly debanked.⁸
• Codification of the reputation-risk prohibition. The OCC and FDIC followed with a joint final rule codifying the prohibition on reputation-risk-based supervision, effective June 9, 2026, making the elimination of reputation risk a binding regulatory standard rather than an internal policy that a future administration could quietly reverse.⁹
• GENIUS Act (enacted July 18, 2025). Federal stablecoin legislation is no longer a pending proposal; the GENIUS Act is now enacted law (Pub. L. 119-27). It is not yet operative: most provisions take effect on the earlier of January 18, 2027, or 120 days after the primary federal regulators issue final implementing regulations, and the agencies began issuing proposed implementing rules in early-to-mid 2026. Stablecoin issuers should treat the federal framework as enacted-but-not-yet-effective and build toward it now (see our GENIUS Act compliance roadmap).

Taken together, these developments are a genuine and well-documented regulatory thaw, not a rhetorical one. But two cautions are warranted. First, regulatory permission is not the same as a bank saying yes. Many traditional institutions remain risk-averse toward crypto clients for reasons of their own, and operational friction at the account-opening and account-maintenance stages persists. Second, crypto companies, regardless of compliance posture, still report periodic denial of banking, lending, and payment services with minimal explanation.¹⁰ The thaw has lowered the regulatory barriers; it has not solved the problem.

The practical message for 2026 is unchanged in spirit: securing and keeping banking requires demonstrating that your company is not merely compliant, but conspicuously and durably compliant.

The Banking Landscape in 2026

Crypto-Friendly Banks (U.S.)

The U.S. crypto-banking landscape has consolidated around a handful of specialized institutions and fintech platforms. The figures below (minimums, fees, and timelines) are approximate practitioner estimates as of 2026; confirm them directly with the institution.

Mercury (via partner banks)

• Focus: Fast-scaling Web3 startups, DeFi, and NFT companies
• Strengths: Tech-forward banking platform, integrations across the crypto ecosystem, streamlined onboarding
• Recent Developments: Raised a $300 million Series C in March 2025 at a roughly $3.5 billion valuation¹¹
• Note: Mercury holds customer funds at FDIC-insured partner banks; during the 2024 turmoil in the banking-as-a-service sector, it moved customer accounts among partner banks
• Account Minimums: Typically $25K-$50K for startups (approximate; confirm with Mercury)
• Application Timeline: Roughly 2-4 weeks with complete documentation

Customers Bank

• Focus: Institutional digital-asset clients
• Strengths: Real-time payment rails and banking APIs for crypto platforms; an established institutional crypto-banking franchise
• Innovations: The Customers Bank Instant Token (CBIT) supports real-time USD payments between institutional clients
• Important caveat: Customers Bank is a real institutional crypto banker that has also been under heightened regulatory scrutiny. On August 5, 2024 (announced August 8, 2024), the Federal Reserve entered a Written Agreement with Customers Bancorp and Customers Bank citing significant deficiencies in the bank’s risk-management and BSA/AML/OFAC compliance tied to its digital-asset business, and requiring remediation and the engagement of an independent transaction-review consultant.¹² Diligence this relationship carefully, and ask about the status of that remediation
• Account Minimums: $100K-$250K, institutional focus (approximate; confirm with the bank)
• Application Timeline: Roughly 6-12 weeks with extensive due diligence
• Best For: Established exchanges, stablecoin issuers, and large-scale custody providers

Cross River Bank

• Focus: Fintech infrastructure and crypto payment processors
• Strengths: API-first banking, extensive compliance infrastructure, regulatory experience
• Account Minimums: $50K-$100K (approximate; confirm with the bank)
• Application Timeline: Roughly 4-8 weeks
• Best For: Crypto payment processors and fintech platforms integrating digital assets

JPMorgan Chase (selective)

• Focus: Large institutional clients only, typically for corporate cash management
• Strengths: Deep liquidity, full-service traditional banking, institutional credibility
• Limitations: Not accessible to early-stage companies; expects significant revenue and institutional backing
• Best For: Public crypto companies and large institutional players

Regional & Community Banks (case-by-case)

• Some regional banks (notably in Texas, Wyoming, and Florida) have developed crypto expertise
• Relationship-driven; often require in-person meetings and a local presence
• Application process varies widely (roughly 4-16 weeks)
• Account minimums approximately $25K-$100K (confirm with the bank)

National Banks That Remain Cautious

Several large national banks have historically maintained restrictive policies toward crypto-related accounts, and applications from crypto companies have often been declined or subjected to significant restrictions. The 2025-2026 regulatory thaw has begun to soften some of this posture, but caution at the largest institutions persists and varies by line of business. Confirm a given bank’s current appetite directly rather than assuming either a blanket “no” or a blanket “yes.”

The Partner Bank Model

Many crypto companies access banking through fintech partners (Mercury, Stripe Treasury, and similar platforms) that provide the customer interface while holding funds at FDIC-insured partner banks.

Advantages:

• Faster onboarding (often 2-4 weeks versus 8-12 weeks for a direct bank relationship)
• Modern API integrations
• Better user experience

Disadvantages:

• Dependent on the fintech’s relationship with the underlying bank
• Less control if partner-bank relationships change
• Exposure to disruption when partner banks exit or a provider in the banking-as-a-service chain fails, as the 2024 sector turmoil demonstrated

Recommendation: Use a partner-bank fintech as your primary banking channel if it fits, but maintain a backup direct banking relationship.

Bank Requirements Checklist

Banks evaluating crypto company applications focus on three core questions:

1. Regulatory Compliance: Does this company meet BSA/AML requirements?
2. Business Model Risk: How exposed are we to crypto volatility and regulatory uncertainty?
3. Operational and Safety-and-Soundness Risk: Will this relationship create meaningful regulatory or operational risk we cannot manage?

A note on that third question. Through 2024, banks often framed the concern as “reputational risk.” With the OCC’s March 2025 removal of reputation risk from the Comptroller’s Handbook, the August 2025 Executive Order, and the OCC/FDIC final rule codifying the prohibition effective June 9, 2026, examiners are no longer supposed to criticize a bank on reputation-risk grounds. In practice, expect banks to reframe the same underlying concerns in safety-and-soundness and BSA/AML terms. Prepare to answer the substance, not the label.

Essential Documents

Corporate Formation & Governance:

• Articles of incorporation or organization
• Operating agreement or bylaws
• Cap table and ownership structure
• List of all directors and officers with backgrounds
• Board resolutions authorizing the banking relationship

Business Operations:

• Detailed business plan (including crypto-specific activities)
• Revenue model and financial projections (three-year)
• Current financial statements (audited if available)
• Customer demographics and geographic markets
• Transaction volume projections (daily, monthly, annual)
• Source-of-funds analysis

Compliance Program:

• Written AML/CFT compliance manual (BSA-compliant)
• Customer identification program (CIP) procedures
• Transaction monitoring procedures and thresholds
• Suspicious activity reporting (SAR) procedures
• OFAC screening procedures
• Know Your Customer (KYC) documentation standards
• Employee training program documentation
• Designated compliance officer (with resume)

Regulatory Status:

• Money transmitter licenses (in states where operating)
• FinCEN MSB registration (if applicable)
• State-specific digital asset licenses (e.g., NY BitLicense)
• Legal opinion letter (confirming regulatory compliance)
• Evidence of regulatory examinations (if applicable)

Technology & Security:

• Information security policy and procedures
• Data breach response plan
• Third-party security audits (SOC 2 Type II ideal)
• Cybersecurity insurance (typically $1M+ coverage)
• Wallet security and custody arrangements

Professional Relationships:

• Engagement letter with specialized crypto legal counsel
• Engagement letter with an accounting firm (Big 4 or crypto-specialized preferred)
• Professional liability insurance (E&O coverage)
• Cyber liability insurance

Account Minimums & Fees

The figures below are approximate practitioner estimates as of 2026 and vary widely by institution, business profile, and transaction volume. Treat them as illustrative, not authoritative, and confirm current terms directly with each institution.

Typical Initial Deposits:

• Startup (pre-revenue): roughly $25K-$50K minimum
• Established (under $10M revenue): roughly $50K-$100K minimum
• Institutional ($10M+ revenue): roughly $100K-$250K minimum

Monthly Maintenance Fees:

• Basic business accounts: approximately $50-$200/month
• Enhanced monitoring accounts: approximately $500-$2,000/month
• Institutional accounts: approximately $2,000-$10,000/month, depending on volume

Transaction Fees (approximate):

• Wire transfers: roughly $15-$35 outgoing, $10-$15 incoming
• ACH transfers: roughly $0.25-$1.00 per transaction
• International wires: roughly $35-$75

Application Strategy: How to Position Your Business

The difference between approval and rejection often comes down to how you present your business, not what your business does.

Frame Your Business Accurately and Precisely

The goal is accurate, precise framing that foregrounds the regulated, infrastructure-oriented nature of your business, not euphemism.

Weak framing:

• “We’re a cryptocurrency exchange”
• “We help people buy Bitcoin”
• “We’re building DeFi protocols”

Stronger framing:

• “We provide financial-technology infrastructure for digital-asset management”
• “We offer regulatory-compliant digital-asset custody and settlement services”
• “We operate a licensed money services business specializing in blockchain-based payment solutions”

Key Principle: Emphasize compliance, technology infrastructure, and regulatory adherence over speculation, while describing your activities truthfully. Banks will diligence the substance; a frame that the diligence contradicts is worse than no frame at all.

Highlight Compliance as a Competitive Advantage

Banks want to hear that you view compliance as a business imperative, not a burden.

Effective Positioning:

• “We have invested substantially in our compliance program, beyond the baseline our size would require”
• “Our Chief Compliance Officer previously led AML programs at an established financial institution”
• “We conduct internal audits and an annual third-party compliance review”
• “Our transaction monitoring system flags activity well below regulatory thresholds”

Demonstrate Regulatory Engagement

Positive Signals:

• Active state money transmitter licenses (not merely pending applications)
• Completed regulatory examinations with clean findings
• Proactive engagement with state regulators
• Industry association memberships (e.g., the Blockchain Association, the Chamber of Digital Commerce)

Red Flags to Avoid:

• Pending regulatory investigations or enforcement actions
• Operating without required licenses (“we’re applying”)
• An adversarial relationship with regulators
• A pattern of SAR filings against the company at prior financial institutions

Emphasize Institutional Partnerships

Banks evaluate your business in part by the company you keep.

Credibility Signals:

• Custody relationships with licensed qualified custodians (see our guide)
• Insurance policies from reputable carriers
• Legal counsel from recognized crypto law firms
• Accounting services from Big 4 or specialized crypto firms
• Compliance and analytics vendors with banking clients (e.g., Chainalysis, Elliptic, TRM Labs)

Prepare for the “What If Crypto Crashes?” Question

Banks worry that crypto volatility could create liquidity crises or mass customer withdrawals.

Effective Response:

• “We maintain full fiat reserves for customer deposits; we do not hold speculative crypto positions”
• “Our revenue model is fee-based (transaction and custody fees), not dependent on crypto price appreciation”
• “We have stress-tested our business model against a severe decline in crypto asset values and remain viable”
• “We maintain diversified banking relationships and meaningful working-capital reserves”

Crypto-Friendly Bank Comparison

The minimums and timelines below are approximate practitioner estimates as of 2026; confirm directly with each institution.

Reality Check: Even “crypto-friendly” banks decline a large share of applications. The regulatory thaw has widened the door; preparation and positioning still determine whether you get through it.

Maintaining Banking Relationships

Securing banking is only half the battle. Maintaining it requires ongoing compliance discipline and proactive relationship management.

Periodic Reporting Requirements

Most crypto-banking relationships require periodic compliance reporting.

Quarterly Deliverables (typical):

• Transaction volume summary (total, average, high-water marks)
• Customer growth metrics (new accounts, jurisdictions)
• Compliance incidents report (SARs filed, accounts closed, alerts triggered)
• Regulatory updates (new licenses, examinations, enforcement contacts)
• Financial statements (P&L, balance sheet, cash flow)
• Updated risk assessment (new products, markets, partnerships)

Annual Deliverables (typical):

• Independent compliance audit results
• Updated AML compliance manual (if procedures changed)
• Employee training records
• Third-party vendor security audits
• Insurance renewal confirmations
• Legal opinion letter (confirming continued compliance)

Proactive Communication:

Notify your bank before making major business changes:

• Launching new products or services
• Entering new geographic markets
• Accepting new asset types (e.g., adding stablecoin support)
• Significant increases in transaction volume
• Changes in ownership or key personnel
• Regulatory examinations or inquiries

Relationship Management Best Practices:

1. Assign a point person: Designate a senior executive (CCO or CFO) as the primary bank contact
2. Schedule regular check-ins: Quarterly calls with your relationship manager, even when not required
3. Respond promptly: Answer bank information requests quickly, typically within a day or two
4. Exceed requirements: Provide more transparency than required
5. Build personal relationships: Meet in person when possible, especially for regional banks

Compliance Updates That Matter

Banks monitor regulatory developments affecting crypto clients. Stay ahead by proactively addressing the following.

2026 Compliance Priorities:

• GENIUS Act readiness: The federal stablecoin framework is enacted but not yet effective. Issuers should build toward the GENIUS Act now rather than waiting for the operative date (see our compliance roadmap)
• State licensing: Notify your bank when obtaining new state money transmitter licenses or expanding operations
• Travel Rule compliance: The existing BSA Travel Rule applies to covered transmittals of funds at or above $3,000 and remains in effect for VASPs and MSBs. Separately, FinCEN’s 2020 proposal to impose recordkeeping and reporting requirements on transactions with self-hosted (unhosted) wallets was withdrawn by Treasury and FinCEN in August 2024; it is not a live rule
• Custody standards: Implement qualified-custodian relationships consistent with evolving federal standards (see our custodian guide)

Monthly Compliance Hygiene:

• Review transaction monitoring alerts (same-day investigation)
• Update OFAC screening lists (daily automated checks)
• Conduct employee training (quarterly minimum)
• Test incident response procedures (quarterly drills)
• Review vendor security attestations (annual SOC 2 renewals)

Red Flags That Get Accounts Closed

Banks monitor crypto accounts for patterns that trigger closure or restriction.

Fatal Mistakes to Avoid

1. Mixing Personal and Business Transactions

Using your business account for personal expenses is among the fastest ways to trigger closure.

What Gets Flagged:

• Personal bill payments (utilities, mortgage, car loans)
• Personal credit card payments
• Transfers to personal investment accounts
• Personal shopping or dining expenses

Why It Matters: Banks cannot perform proper BSA/AML monitoring when personal and business transactions are commingled. This undermines the premise of business-account compliance.

Solution: Maintain strict separation. To pay yourself, use proper payroll or owner’s-draw procedures.

2. Structuring Transactions

Breaking up transactions to evade reporting thresholds is a federal crime (31 U.S.C. § 5324).

What Constitutes Structuring:

• Making multiple sub-$10,000 cash deposits instead of one larger deposit, to evade the $10,000 Currency Transaction Report (CTR) threshold
• Splitting transactions across multiple accounts to stay below monitoring thresholds
• Coordinating with customers to make multiple smaller transactions

Criminal Penalties: Structuring is punishable by up to five years’ imprisonment, plus fines. The maximum rises to ten years if the structuring is committed while violating another federal law, or as part of a pattern of any illegal activity involving more than $100,000 in a twelve-month period.¹³

Bank Response: Likely account closure, a SAR filing, and a potential law-enforcement referral.

Legitimate Business Explanation: If you have genuine business reasons that produce transaction patterns resembling structuring (customer-batch processing, payment-processor limits), document them clearly and notify your bank proactively.

3. High-Risk Jurisdictions

Transactions involving FATF-listed high-risk or monitored jurisdictions trigger enhanced scrutiny. The FATF maintains two relevant lists.

The blacklist (“High-Risk Jurisdictions subject to a Call for Action”) is small and stable: North Korea (DPRK), Iran, and Myanmar.¹⁴

The greylist (“Jurisdictions under Increased Monitoring”) changes at nearly every FATF plenary, which meets roughly three times a year, so any static list dates quickly. Do not rely on a list reproduced in an article. Consult the live FATF “Jurisdictions under Increased Monitoring” page for the current roster before relying on it.¹⁴ As an illustration only, the greylist as of the February 2026 FATF plenary included roughly two dozen jurisdictions, among them Algeria, Venezuela, and Vietnam, with Kuwait and Papua New Guinea added at that plenary. (Current as of February 2026; verify against the live FATF list, which supersedes any example here.)

Bank Expectations:

• Avoid transactions with blacklisted countries entirely
• Apply enhanced due diligence (EDD) for greylisted countries:
  • Document a legitimate business purpose
  • Verify customer identities through additional sources
  • Conduct a source-of-funds investigation
  • Obtain senior-management approval
  • Monitor transactions more frequently

Practical Impact: Many banks simply prohibit crypto companies from any blacklisted- or greylisted-jurisdiction transactions. Confirm your bank’s policy before accepting these customers.

4. Rapid Changes in Transaction Patterns

Sudden spikes in transaction volume trigger automated monitoring alerts.

What Gets Flagged:

• A large, sudden increase in daily transaction volume
• A sudden shift in customer demographics or geographies
• New transaction types (e.g., suddenly processing international wires)
• Significant increases in high-dollar transactions

How to Avoid Problems:

• Notify your bank before anticipated volume increases (product launches, marketing campaigns)
• Provide advance notice of new business lines (adding stablecoin support, new jurisdictions)
• Explain seasonal patterns (tax-season volume, year-end spikes)

5. Unresponsiveness to Bank Inquiries

Banks send information requests regularly. Failure to respond promptly is grounds for restriction or closure.

Typical Inquiries:

• Source of funds for large deposits
• Explanation of unusual transaction patterns
• Documentation of business relationships with specific customers
• Verification of regulatory status

Response Time: Treat urgent inquiries as same-day-to-48-hour items, and routine requests as no more than a few business days.

Consequences of Non-Response (illustrative escalation):

• First missed deadline: a formal warning
• Second missed deadline: account restrictions (frozen transactions)
• Continued non-response: account closure with a wind-down period

6. Negative Media or Regulatory Action

Banks monitor news and regulatory databases for clients involved in enforcement actions or scandals.

Trigger Events:

• SEC or CFTC enforcement actions (even if settled)
• State regulatory investigations or orders
• Negative media coverage (fraud allegations, hacks, customer complaints)
• Bankruptcy filings
• Litigation involving fraud or securities violations

Proactive Strategy:

• Notify your bank promptly if any enforcement action or investigation commences
• Provide your side with legal context so the bank is not left to read news coverage alone
• Demonstrate remediation steps (compliance improvements, management changes)

Backup Banking Strategy

Even in a more favorable regulatory climate, every crypto company should plan for the possibility that a banking relationship could end on short notice (closure terms are often around 30 days).

Multiple Banking Relationships

Recommended Structure:

1. Primary Operating Bank: Your main account for daily operations
2. Backup Operating Bank: A secondary account with a minimum balance, tested quarterly
3. Payroll Bank: A separate account for employee payments, reducing risk if the operating account is frozen
4. Reserve Bank (Traditional): A larger regional or national bank holding operating reserves (six-plus months of expenses)

Cost: Maintaining multiple relationships costs money in minimum balances and fees, but it provides critical redundancy.

Testing Protocol:

• Run at least one transaction per quarter through backup accounts
• Verify that wire transfer access works
• Test ACH processing
• Confirm online banking credentials remain active

Stablecoin Reserve Strategy

Because banking access can still be disrupted, many crypto companies hold a portion of operating reserves in stablecoins.

Operational Model:

• Maintain 30-60 days of operating expenses in stablecoins
• Store at a licensed qualified custodian with institutional access
• Maintain the ability to convert to fiat within 24-48 hours
• Use for emergency liquidity if banking access is interrupted

Legal Considerations:

• Ensure the custody arrangement meets qualified-custodian standards (see our guide)
• Document this strategy in your treasury management policy (see our treasury guide)
• Consider the tax implications of holding stablecoins (consult a tax advisor)
• Ensure proper internal controls over custody access

Advantages:

• Not subject to a single bank’s closure decision
• 24/7 access (no weekend or holiday restrictions)
• Can be moved between custodians quickly
• Reduces single points of failure

Disadvantages:

• A still-developing regulatory framework (the GENIUS Act is enacted but not yet effective)
• Depegging risk (mitigated by diversifying across multiple stablecoins)
• No FDIC insurance (mitigated, in part, by qualified-custodian insurance)

Recommended Allocation (illustrative):

• Fiat banking: roughly 70-80% of operating reserves
• Stablecoin reserves: roughly 20-30% of operating reserves
• Regular rebalancing: quarterly, or when ratios drift materially

Fintech Partner Alternatives

If traditional banking becomes unavailable, consider fintech infrastructure providers, with eyes open to the 2024 banking-as-a-service sector turmoil that disrupted several providers.

Payment Processing (supplementing banking):

• Stripe Treasury: embedded banking-as-a-service, if eligible
• Unit: banking-as-a-service for fintech platforms
• Diligence each provider’s banking-partner chain and financial health; this layer has a recent history of disruption

Crypto-Native Alternatives:

• Stablecoin payment rails: pay vendors and contractors in stablecoins where appropriate
• Crypto payroll services: convert payroll to stablecoins through specialized providers
• On-chain treasury management: on-chain reserves in audited protocols (higher risk; for sophisticated teams only)

International Banking Options

For crypto companies unable to secure U.S. banking, international jurisdictions offer alternatives, with significant compliance tradeoffs.

United Kingdom

Crypto-Friendly Banks:

Revolut (Licensed UK Bank)

• Revolut received a UK banking license with restrictions (the “mobilisation” stage) in July 2024, and exited mobilisation to receive its full UK banking license on March 11, 2026; it is now authorised and regulated by the Prudential Regulation Authority and the Financial Conduct Authority¹⁵
• Supports crypto trading for a range of tokens in-app
• Business accounts available
• Limitations: primarily consumer-focused; business accounts have transaction limits
• Best For: early-stage startups with a UK presence

BCB Group (Specialized Crypto Banking)

• UK-headquartered, with European operations
• Serves digital-asset companies
• Handles institutional settlements
• Requirements: institutional minimums; an established business
• Best For: exchanges, custody providers, institutional players

Clear Junction (Payment Infrastructure)

• UK-headquartered, operating across Europe
• Facilitates cross-border payments for crypto businesses
• API-first infrastructure
• Best For: payment processors and fintech platforms

UK Regulatory Environment:

• The Financial Conduct Authority (FCA) regulates crypto-asset activity and is building out a broader crypto regulatory regime
• Registration is required for AML purposes
• Generally more crypto-receptive than the U.S. historically, though still selective

Switzerland

Switzerland remains a leading jurisdiction for crypto banking, with comprehensive regulatory frameworks and institutional-grade services.

Sygnum Bank (Licensed Swiss Bank)

• Swiss banking license, with a presence in Singapore
• Integrated crypto-fiat accounts (hold major crypto assets alongside fiat)
• Institutional custody, tokenization, and staking services
• Requirements: institutional minimums; extensive due diligence (roughly 12-16 weeks)
• Best For: stablecoin issuers, tokenization platforms, institutional custody

AMINA Bank (formerly SEBA Bank) (Licensed Swiss Crypto Bank)

• Founded 2018, headquartered in Zug (“Crypto Valley”); rebranded from SEBA Bank to AMINA Bank on November 30, 2023
• One of Europe’s first licensed crypto banks
• Supports a broad set of digital assets
• Requirements: institutional minimums; corporate clients only
• Best For: European crypto companies and DeFi projects with Swiss entities

Swiss Regulatory Framework:

• FINMA (the Swiss Financial Market Supervisory Authority) provides comprehensive crypto regulation
• A clear token-classification framework (payment, utility, asset tokens)
• Strong asset protection
• High compliance standards (Swiss-level AML/KYC)

Cost Considerations (approximate):

• Account minimums in the high six figures to low seven figures
• Substantial monthly fees, depending on services
• Setup timeline of roughly 12-20 weeks
• A Swiss legal-entity requirement (subsidiary or parent)

Singapore

Singapore is a major Asian crypto-banking hub with a clear regulatory framework.

DBS Bank

• A major Southeast Asian bank offering institutional digital-asset services, including trading, custody, and tokenization
• Institutional-grade infrastructure
• Requirements: corporate accounts only; significant minimums
• Best For: Asia-focused crypto companies, stablecoin issuers, institutional custody

Regulatory Environment:

• The Payment Services Act (PSA) licensing framework
• Monetary Authority of Singapore (MAS) oversight
• A clear regulatory regime and a business-friendly environment
• Consult a Singapore tax advisor on the applicable corporate and transactional tax treatment

Strategic Considerations:

• Well-suited for companies targeting Asian markets
• An English-language business environment
• Strong IP protection and rule of law
• A relatively expensive jurisdiction (high operational costs)

Compliance Considerations for International Banking

U.S. Companies Using International Banks:

Even with foreign banking, U.S. crypto companies remain subject to:

• FBAR reporting: FinCEN FBARs for foreign financial accounts exceeding $10,000 in the aggregate
• FATCA compliance: Foreign Account Tax Compliance Act reporting
• State MTL requirements: a foreign banking location does not eliminate U.S. licensing obligations
• Tax reporting: IRS reporting on all income regardless of banking location

Advantages of International Banking:

• More stable banking relationships, less exposed to U.S. policy shifts
• Institutional-grade crypto services (custody, staking, trading)
• Regulatory clarity in crypto-forward jurisdictions
• Access to an international customer base

Disadvantages:

• High minimums and fees
• Extended timelines (often 12-20 weeks)
• A foreign-entity requirement (subsidiary or parent)
• Complex tax and reporting obligations
• Time-zone and language challenges (somewhat mitigated in the UK and Singapore)

Recommended Strategy: U.S. companies with international ambitions should consider establishing a Swiss or Singapore entity proactively, before banking becomes critical, allowing 6-12 months for entity formation and banking applications.

What to Do If You Lose Banking Access

Despite best efforts, account closures still happen. A response plan is essential.

Immediate Actions (Day 1-7)

1. Request a Written Explanation

• Banks are generally not required to provide reasons for closure, but request formal written notice
• Document all communications (emails, calls, letters)
• Note the effective closure date (often around 30 days)

2. Secure Access to Funds

• Confirm you can withdraw funds (via wire, ACH, or check)
• Identify the final date for transaction processing
• Transfer funds to a backup bank account immediately

3. Notify Key Stakeholders

• Inform investors and the board of directors
• Notify legal counsel
• Alert your accounting team
• Brief your compliance officer

4. Activate Backup Banking

• Transfer operations to your secondary banking relationship
• Update payment-processor credentials
• Redirect ACH transactions
• Notify vendors of updated wire instructions

5. Evaluate Your Options with Counsel

• If the closure may relate to a SAR filing, recognize that SAR-driven closures are difficult to reverse
• Work with legal counsel to evaluate any appeal or escalation options
• Document your compliance efforts for future applications

Short-Term Response (Week 2-4)

6. Conduct an Internal Investigation

• Review recent transactions for potential red flags
• Audit compliance procedures for gaps
• Interview employees about any unusual activity
• Engage outside counsel for an independent assessment if needed

7. Remediate Compliance Gaps

• Update the AML compliance manual based on findings
• Enhance transaction-monitoring procedures
• Implement additional controls
• Document all improvements (critical for the next banking application)

8. Apply to Alternative Banks

• Prioritize crypto-friendly regional banks
• Consider fintech partner-banking options
• Explore international banking (Switzerland, Singapore, UK) if domestic options are exhausted
• Be transparent about the prior closure; banks will discover it regardless

9. Communicate with Customers (if applicable)

• Notify customers of any potential temporary service disruptions
• Provide updated payment instructions
• Reassure customers that their funds remain secure
• Consider temporarily pausing new-customer onboarding until banking stabilizes

Long-Term Strategy (Month 2+)

10. Rebuild Banking Relationships

• Work with legal counsel to craft an accurate narrative about the prior closure
• Emphasize the compliance improvements you implemented
• Provide third-party audit results confirming enhanced controls
• Target banks with existing crypto expertise, which are more likely to understand industry challenges

11. Diversify Banking Infrastructure

• Never again rely on a single banking relationship
• Implement three to four banking relationships with staged reserves
• Increase your stablecoin reserve allocation as a redundancy measure
• Consider international banking for critical redundancy

12. Consider Strategic Alternatives

• Evaluate a merger with, or acquisition by, a company with established banking
• Consider licensing existing fintech infrastructure (white-label solutions)
• Explore industry-consortium banking efforts (shared infrastructure)

13. Engage Regulators Proactively (if appropriate)

• Consider requesting meetings with state banking regulators
• Demonstrate compliance investments to FinCEN, if MSB-registered
• Participate in industry working groups (the Blockchain Association, the Chamber of Digital Commerce)
• Build relationships with regulatory officials before the next crisis

Related Resources

For deeper dives into related compliance topics:

• Money Transmitter Licensing Guide - state-by-state licensing strategy for crypto companies
• Qualified Crypto Custodians - custody relationships that satisfy banking partners
• GENIUS Act Stablecoin Compliance Roadmap - federal stablecoin requirements for issuers
• Treasury Management for Crypto Companies - comprehensive treasury strategies including banking relationships
• Fintech & Payments Practice Area - our regulatory compliance services for fintech and payments companies
• Regulatory Compliance Practice Area - comprehensive compliance program development

Final Thoughts: Banking as a Strategic Advantage

In 2026, the crypto companies that succeed treat banking relationships as a strategic asset requiring continuous investment, not a commodity service to take for granted. The regulatory thaw of 2025-2026 has improved the landscape, but the durable advantage still belongs to the disciplined.

The companies I work with that maintain uninterrupted banking access tend to share common characteristics:

• A compliance-first culture (not just lip service)
• Proactive communication with banking partners
• Redundant infrastructure (multiple banking relationships, stablecoin reserves)
• Professional advisors (legal, accounting, compliance)
• Realistic risk management (understanding that banking is never guaranteed)

Banking remains one of the most significant operational risks for crypto companies, even as the regulatory posture has improved. With thoughtful planning, robust compliance, and strategic diversification, banking obstacles can be navigated successfully.

The 2025-2026 thaw, anchored by OCC Interpretive Letter 1183, the August 2025 Executive Order, the codification of the reputation-risk prohibition, and the enactment of the GENIUS Act, signals a real and documented improvement in crypto banking access. But even in a more favorable regulatory climate, banking relationships require careful cultivation and ongoing maintenance.

Treat your banking relationships with the seriousness they deserve. Your business depends on it.

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Need help securing banking for your crypto company? Our firm helps digital-asset companies develop compliance programs, prepare banking applications, and maintain relationships that last. Contact us to discuss your banking strategy.

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Disclaimer: This article provides general information for educational purposes only and does not constitute legal advice. Banking regulations and crypto policies are evolving rapidly. Consult qualified legal counsel for advice on your specific situation.

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Footnotes

1. FDIC, “FDIC Releases Documents Related to Supervision of Crypto-Related Activities” (Feb. 5, 2025), available at https://www.fdic.gov/news/press-releases/2025/fdic-releases-documents-related-supervision-crypto-related-activities; see also FDIC, “Correspondence Related to Crypto-Related Activities,” available at https://www.fdic.gov/foia/correspondence-related-crypto-related-activities (collecting the released records, including correspondence with the approximately 24 institutions that received “pause” letters). ↩

2. Board of Governors of the Federal Reserve System, “Federal Reserve Board fines Silvergate Bank” (July 1, 2024), available at https://www.federalreserve.gov/newsevents/pressreleases/enforcement20240701a.htm; California Department of Financial Protection and Innovation, “Silvergate to Pay $63 Million in Combined Penalties” (July 1, 2024), available at https://dfpi.ca.gov/press_release/silvergate-to-pay-63-million-in-combined-penalties-following-coordinated-investigations-by-dfpi-federal-partners/. ↩

3. New York Community Bancorp / Flagstar acquisition of certain Signature Bank assets (Mar. 2023); see “Flagstar Bank to buy some Signature Bank assets, but not crypto operations,” TechCrunch (Mar. 20, 2023), available at https://techcrunch.com/2023/03/20/flagstar-bank-to-buy-some-signature-bank-assets-but-not-crypto-operations/. ↩

4. OCC, “OCC Clarifies Bank Authority to Engage in Certain Cryptocurrency Activities,” News Release 2025-16 (Mar. 7, 2025), available at https://www.occ.treas.gov/news-issuances/news-releases/2025/nr-occ-2025-16.html; OCC Interpretive Letter 1183 (Mar. 2025), available at https://www.occ.gov/topics/charters-and-licensing/interpretations-and-decisions/2025/int1183.pdf (rescinding Interpretive Letter 1179 and removing the supervisory non-objection condition). ↩

5. OCC, Bulletin 2025-4, “Bank Supervision: Removing References to Reputation Risk” (Mar. 20, 2025), available at https://www.occ.gov/news-issuances/bulletins/2025/bulletin-2025-4.html. ↩

6. FDIC, Financial Institution Letter FIL-7-2025, “FDIC Clarifies Process for Banks to Engage in Crypto-Related Activities” (Mar. 28, 2025), available at https://www.fdic.gov/news/financial-institution-letters/2025/fdic-clarifies-process-banks-engage-crypto-related (rescinding FIL-16-2022). ↩

7. Board of Governors of the Federal Reserve System, “Federal Reserve Board announces the withdrawal of guidance for banks related to their crypto-asset and dollar token activities” (Apr. 24, 2025), available at https://www.federalreserve.gov/newsevents/pressreleases/bcreg20250424a.htm (rescinding SR 22-6 and SR 23-8 and withdrawing, with the FDIC, from the January and February 2023 interagency joint statements). ↩

8. Exec. Order No. 14331, “Guaranteeing Fair Banking For All Americans” (Aug. 7, 2025), available at https://www.whitehouse.gov/presidential-actions/2025/08/guaranteeing-fair-banking-for-all-americans/; see also 90 Fed. Reg. 38,925 (Aug. 12, 2025), available at https://www.federalregister.gov/documents/2025/08/12/2025-15341/guaranteeing-fair-banking-for-all-americans. ↩

9. OCC & FDIC, “Prohibition on the Use of Reputation Risk by Regulators,” Final Rule; see OCC Bulletin 2026-12 (Apr. 2026), available at https://www.occ.gov/news-issuances/bulletins/2026/bulletin-2026-12.html; final rule published at 91 Fed. Reg. 18,279 (Apr. 10, 2026), available at https://www.federalregister.gov/documents/2026/04/10/2026-06947/prohibition-on-the-use-of-reputation-risk-by-regulators (effective June 9, 2026). ↩

10. See, e.g., reporting that crypto companies continued to report banking, lending, and payment-service denials notwithstanding the 2025 regulatory shifts, “Operation Chokepoint 2.0 Is Not Dead,” available at https://bitcoinethereumnews.com/tech/operation-chokepoint-2-0-is-not-dead/. ↩

11. “Mercury raises $300M Series C at a $3.5B valuation,” TechCrunch (Mar. 26, 2025), available at https://techcrunch.com/2025/03/26/banking-startup-mercury-raises-300m-series-c-at-3-5b-valuation/. ↩

12. Board of Governors of the Federal Reserve System, Written Agreement with Customers Bancorp, Inc. and Customers Bank (executed Aug. 5, 2024; announced Aug. 8, 2024), available at https://www.federalreserve.gov/newsevents/pressreleases/enforcement20240808a.htm (citing significant deficiencies in risk-management and BSA/AML/OFAC compliance tied to the bank’s digital-asset business and requiring an independent transaction-review consultant). ↩

13. 31 U.S.C. § 5324 (structuring transactions to evade reporting requirements; enhanced penalty of up to ten years where the violation is committed while violating another law of the United States or as part of a pattern of any illegal activity involving more than $100,000 in a twelve-month period). The $10,000 Currency Transaction Report threshold appears at 31 U.S.C. § 5313 and 31 C.F.R. § 1010.311. ↩

14. Financial Action Task Force (FATF), “High-Risk and Other Monitored Jurisdictions,” available at https://www.fatf-gafi.org/en/publications/High-risk-and-other-monitored-jurisdictions.html (maintaining both the “High-Risk Jurisdictions subject to a Call for Action” list and the regularly updated “Jurisdictions under Increased Monitoring” list; consult the live page for the current roster). ↩ ↩²

15. “Revolut acquires full UK banking license after years-long wait,” CNBC (Mar. 11, 2026), available at https://www.cnbc.com/2026/03/11/revolut-acquires-full-uk-banking-license.html (Revolut exited the July 2024 “mobilisation” stage to receive a full UK banking license on March 11, 2026). ↩