Crypto Banking Relationships: How to Get and Keep Bank Accounts

By Chanté Eliaszadeh | October 15, 2025

Banking access remains the single most challenging operational hurdle for cryptocurrency companies in 2025. While the regulatory environment has improved since the darkest days of "Operation Chokepoint 2.0" in 2023-2024, securing and maintaining banking relationships still requires strategic planning, robust compliance programs, and careful relationship management.

I've guided dozens of crypto companies through the banking application process, from early-stage startups to established exchanges. The difference between companies that successfully obtain banking and those that don't comes down to preparation, positioning, and ongoing compliance discipline.

This guide provides a practical roadmap for crypto companies seeking banking relationships, based on real-world experience with what actually works in 2025.

Why Crypto Companies Struggle with Banking

The coordinated federal effort to de-bank crypto companies—dubbed "Operation Chokepoint 2.0"—was real. Internal FDIC communications released in December 2024 revealed concerted pressure on banks to sever relationships with digital asset companies following the March 2023 failures of Silvergate, Signature, and Silicon Valley Bank.¹

The impact was devastating: Signature Bank's $4 billion in crypto deposits were explicitly excluded from the Flagstar acquisition, and the FDIC instructed customers to close their Signet digital banking accounts.² Two of the industry's most sophisticated crypto-banking platforms disappeared overnight.

Current State of Play (2025):

• Policy Shift: The OCC eased restrictions in March 2025, clarifying that crypto-asset custody, stablecoin activities, and blockchain node participation are permissible for national banks and federal savings associations.³
• Lingering Challenges: Despite regulatory clarifications, most traditional banks remain risk-averse toward crypto clients. Banking access has improved but remains constrained compared to pre-2023 levels.
• Systemic Barriers: Crypto companies—regardless of compliance status—continue reporting denial of banking, lending, and payment services with minimal explanation.⁴

The message is clear: securing banking in 2025 requires demonstrating that your company is not just compliant, but exceptionally compliant.

The Banking Landscape in 2025

Crypto-Friendly Banks (U.S.)

The U.S. crypto-banking landscape has consolidated around a handful of specialized institutions:

Mercury (via partner banks)

• Focus: Fast-scaling Web3 startups, DeFi, NFT companies
• Strengths: Tech-forward banking platform, integrations with Coinbase and Kraken, streamlined onboarding
• Recent Developments: Secured $300 million funding round in early 2025, reaching $3.5B valuation and $500M annual revenue⁵
• Note: Transitioned accounts from Evolve Bank (following 2024 data breach) to Column N.A. and other FDIC-insured partners
• Account Minimums: Typically $25K-$50K for startups
• Application Timeline: 2-4 weeks with complete documentation

Customers Bank

• Focus: Institutional clients (Coinbase, Circle, Galaxy Digital)
• Strengths: Real-time payment rails, banking APIs for crypto platforms, institutional custody connections
• Innovations: Customer Bank's Instant Token (CBIT) enables real-time USD payments via partnership with Kraken⁶
• Account Minimums: $100K-$250K (institutional focus)
• Application Timeline: 6-12 weeks with extensive due diligence
• Best For: Established exchanges, stablecoin issuers, large-scale custody providers

Cross River Bank

• Focus: Fintech infrastructure, crypto payment processors
• Strengths: API-first banking, extensive compliance infrastructure, regulatory expertise
• Account Minimums: $50K-$100K
• Application Timeline: 4-8 weeks
• Best For: Crypto payment processors, fintech platforms integrating digital assets

JPMorgan Chase (selective)

• Focus: Large institutional clients only (Coinbase, Gemini for corporate cash management)
• Strengths: Deep liquidity, traditional banking services, institutional credibility
• Limitations: Not accessible to early-stage companies; requires significant revenue and institutional backing
• Best For: Public crypto companies, large institutional players

Regional & Community Banks (case-by-case)

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

National Banks to Avoid (for Now)

Wells Fargo, Bank of America, US Bank, PNC: These institutions continue maintaining restrictive policies on crypto-related accounts. Applications from crypto companies are typically declined automatically or subject to prohibitive restrictions.

The Partner Bank Model

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

Advantages:

• Faster onboarding (2-4 weeks vs. 8-12 weeks direct)
• Modern API integrations
• Better user experience

Disadvantages:

• Dependent on fintech's relationship with underlying bank
• Less control if partner bank relationships change
• Potential for disruption (Evolve data breach, partner bank exits)

Recommendation: Use partner-bank fintech as primary banking but maintain 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. Reputational Risk: Will this relationship create regulatory scrutiny or public backlash?

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 banking relationship

Business Operations:

• Detailed business plan (including crypto-specific activities)
• Revenue model and financial projections (3-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 (states where operating)
• FinCEN MSB registration (if applicable)
• State-specific digital asset licenses (e.g., NY BitLicense, CA DFAL)
• 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 ($1M+ coverage typical)
• Wallet security and custody arrangements

Professional Relationships:

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

Account Minimums & Fees

Typical Initial Deposits:

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

Monthly Maintenance Fees:

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

Transaction Fees:

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

❌ DON'T SAY:

• "We're a cryptocurrency exchange"
• "We help people buy Bitcoin"
• "We're building DeFi protocols"

✅ DO SAY:

• "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 crypto trading or speculation.

Highlight Compliance as Competitive Advantage

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

Effective Positioning:

• "We've invested $500K in our compliance program, exceeding industry standards"
• "Our Chief Compliance Officer previously led AML programs at [established financial institution]"
• "We conduct quarterly internal audits and annual third-party compliance reviews"
• "Our transaction monitoring system flags any activity 50% below regulatory thresholds"

Demonstrate Regulatory Engagement

Positive Signals:

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

Red Flags to Avoid:

• Pending regulatory investigations or enforcement actions
• Operating without required licenses ("we're applying")
• Adversarial relationship with regulators
• History of SAR filings at previous financial institutions

Emphasize Institutional Partnerships

Banks evaluate your business 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
• Technology vendors with banking clients (Chainalysis, Elliptic, TRM Labs)

Prepare for the "What If Crypto Crashes?" Question

Banks fear crypto volatility creating liquidity crises or mass customer withdrawals.

Effective Response:

• "We maintain 100% fiat reserves for customer deposits; we don't hold speculative crypto positions"
• "Our revenue model is fee-based (transaction fees, custody fees), not dependent on crypto price appreciation"
• "We've stress-tested our business model assuming 80% decline in crypto asset values; we remain profitable"
• "We maintain diversified banking relationships and $X million in working capital reserves"

Crypto-Friendly Bank Comparison

Reality Check: Even "crypto-friendly" banks reject 60-70% of applications. The difference is preparation and positioning.

Maintaining Banking Relationships

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

Quarterly Reporting Requirements

Most crypto-banking relationships require periodic compliance reporting:

Quarterly Deliverables:

• 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:

• 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 primary bank contact
2. Schedule regular check-ins: Quarterly calls with relationship manager (even when not required)
3. Respond promptly: Answer bank information requests within 24-48 hours
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 for regulatory changes affecting crypto clients. Stay ahead by proactively addressing:

2025 Compliance Priorities:

• GENIUS Act Implementation: Stablecoin issuers should proactively demonstrate compliance with new federal framework (see our compliance roadmap)
• State Licensing Expansion: Notify bank when obtaining new state MTLs or expanding operations
• AML Rule Updates: FinCEN's proposed "travel rule" for crypto transactions (self-hosted wallet regulations)
• Custody Standards: Implement qualified custodian relationships meeting GENIUS Act 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 suspicious patterns that trigger closure or restriction.

Fatal Mistakes to Avoid

1. Mixing Personal and Business Transactions

Using your business account for personal expenses is the fastest way 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 violates the fundamental premise of business account compliance.

Solution: Maintain strict separation. If you need to pay yourself, use proper payroll or owner's draw procedures.

2. Structuring Transactions

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

What Constitutes Structuring:

• Making multiple $9,000 cash deposits instead of one $30,000 deposit (to avoid $10K CTR threshold)
• Splitting wire transfers across multiple accounts to stay below monitoring thresholds
• Coordinating with customers to make multiple smaller transactions

Criminal Penalties: Up to 5 years imprisonment + fines (10 years if part of other illegal activity)

Bank Response: Immediate account closure + SAR filing + potential law enforcement referral

Legitimate Business Explanation: If you have business reasons for transaction structuring (processing customer batches, payment processor limits), document this clearly and notify your bank proactively.

3. High-Risk Jurisdictions

Transactions involving FATF-blacklisted or high-risk jurisdictions trigger enhanced scrutiny.

2025 FATF High-Risk Jurisdictions:⁷

• Blacklist (Call for Action): North Korea, Iran, Myanmar
• Greylist (Increased Monitoring): Afghanistan, Albania, Barbados, Burkina Faso, Cambodia, Cayman Islands, Democratic Republic of Congo, Gibraltar, Haiti, Jamaica, Jordan, Mali, Morocco, Mozambique, Nigeria, Panama, Philippines, Senegal, South Africa, South Sudan, Syria, Tanzania, Trinidad and Tobago, Turkey, Uganda, UAE, Vietnam, Yemen

Bank Expectations:

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

Practical Impact: Many banks simply prohibit crypto companies from any blacklisted/greylist 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:

• 10x increase in daily transaction volume
• 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. Unresponsive to Bank Inquiries

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

Typical Inquiries:

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

Required Response Time: 24-48 hours for urgent inquiries, 5 business days maximum for routine requests

Consequences of Non-Response:

• First missed deadline: Formal warning
• Second missed deadline: Account restrictions (frozen transactions)
• Third missed deadline: Account closure + 30-day 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 immediately if any enforcement action or investigation commences
• Provide your side of the story with legal context (don't leave bank to read news coverage alone)
• Demonstrate remediation steps (compliance improvements, management changes)

Backup Banking Strategy

Every crypto company should operate under the assumption that banking access could disappear with 30 days' notice (typical account closure terms).

Multiple Banking Relationships

Recommended Structure:

1. Primary Operating Bank: Main account for daily operations (Mercury, Cross River, etc.)
2. Backup Operating Bank: Secondary account with minimum balance, tested quarterly
3. Payroll Bank: Separate account for employee payments (reduces risk if operating account frozen)
4. Reserve Bank (Traditional): Large regional or national bank holding operating reserves (6+ months expenses)

Cost: Maintaining multiple relationships costs $500-$2,000/month in minimum balances and fees, but provides critical redundancy.

Testing Protocol:

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

Stablecoin Reserve Strategy

As banks have become unreliable for crypto companies, many are holding operating reserves in stablecoins.

Operational Model:

• Maintain 30-60 days operating expenses in stablecoins (USDC, USDT)
• Store at licensed qualified custodian with institutional access
• Maintain ability to convert to fiat within 24-48 hours
• Use for emergency liquidity if banking access interrupted

Legal Considerations:

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

Advantages:

• Not subject to bank closure decisions
• 24/7 access (no weekend/holiday restrictions)
• Can be moved between custodians quickly
• Reduces single point of failure

Disadvantages:

• Regulatory uncertainty around stablecoin classification
• Potential depegging risk (mitigated by diversifying across multiple stablecoins)
• No FDIC insurance (mitigated by qualified custodian insurance)

Recommended Allocation:

• Fiat banking: 70-80% of operating reserves
• Stablecoin reserves: 20-30% of operating reserves
• Regular rebalancing: Quarterly or when ratios drift >10%

Fintech Partner Alternatives

If traditional banking closes entirely, consider fintech infrastructure providers:

Payment Processing (replacing banking):

• Stripe Treasury: Embedded banking-as-a-service (if eligible)
• Unit: Banking-as-a-service for fintech platforms
• Synapse: Fintech infrastructure (note: experienced service disruptions in 2024)

Crypto-Native Alternatives:

• Stablecoin payment rails: Pay vendors/contractors in USDC
• Crypto payroll services: Bitwage, Rise (convert payroll to stablecoins)
• DeFi treasury management: Onchain reserves in audited protocols (high risk, only for sophisticated teams)

International Banking Options

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

United Kingdom

Crypto-Friendly Banks:

Revolut (Licensed UK Bank)

• Full UK banking license as of 2025
• Supports 130+ crypto tokens in-app
• Business accounts available
• Limitations: Primarily consumer-focused; business accounts have transaction limits
• Best For: Early-stage startups with UK presence

BCB Group (Specialized Crypto Bank)

• Headquarters in UK with Swiss and EU operations
• Serves 30+ digital asset companies
• Handles billions in institutional settlements
• Requirements: Institutional minimums ($500K+), established business
• Best For: Exchanges, custody providers, institutional players

Clear Junction (Payment Infrastructure)

• UK-headquartered, operates across Europe
• Facilitates cross-border payments for crypto exchanges
• API-first infrastructure
• Best For: Payment processors, fintech platforms

UK Regulatory Environment:

• Financial Conduct Authority (FCA) regulates crypto as of 2024
• Registration required for AML compliance
• Generally more crypto-friendly than U.S. but still restrictive

Switzerland

Switzerland remains the gold standard for crypto banking, with comprehensive regulatory frameworks and institutional-grade services.

Sygnum Bank (Licensed Swiss Bank)

• Full Swiss banking license + MAS license (Singapore)
• Integrated crypto-fiat accounts (hold BTC, ETH, stablecoins alongside CHF/USD)
• Institutional custody, tokenization, staking services
• Requirements: Institutional minimums ($1M+), extensive due diligence (12-16 weeks)
• Best For: Stablecoin issuers, tokenization platforms, institutional custody

SEBA Bank / AMINA Bank (Licensed Swiss Crypto Bank)

• Founded 2018, headquartered in Zug ("Crypto Valley")
• One of Europe's first licensed crypto banks
• Supports 50+ digital assets
• Requirements: $500K+ minimums, corporate clients only
• Best For: European crypto companies, DeFi protocols with Swiss entities

Swiss Regulatory Framework:

• FINMA (Swiss Financial Market Supervisory Authority) comprehensive crypto regulation
• Clear classification framework (payment, utility, asset tokens)
• Robust banking secrecy and asset protection
• High compliance standards (Swiss-level AML/KYC)

Cost Considerations:

• Account minimums: $500K-$2M
• Monthly fees: $5K-$25K (depending on services)
• Setup timeline: 12-20 weeks
• Legal entity requirement: Swiss subsidiary or parent company

Singapore

Singapore has emerged as Asia's crypto banking hub with clear regulatory frameworks.

DBS Bank (Largest Southeast Asia Bank)

• Largest cryptocurrency bank in Southeast Asia by assets (2023 data)
• Comprehensive crypto services: trading, custody, tokenization
• Institutional-grade infrastructure
• Requirements: Corporate accounts only, significant minimums ($250K+)
• Best For: Asia-focused crypto companies, stablecoin issuers, institutional custody

Regulatory Environment:

• Payment Services Act (PSA) licensing framework
• Monetary Authority of Singapore (MAS) oversight
• No capital gains tax on crypto for individuals (corporate tax applies)
• Clear regulatory guidance, business-friendly environment

Strategic Considerations:

• Ideal for companies targeting Asian markets
• English-language business environment
• Strong IP protection and rule of law
• 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:

• FinCEN reporting: FBARs for foreign accounts >$10K aggregate
• FATCA compliance: Foreign Account Tax Compliance Act reporting
• State MTL requirements: Banking location doesn't 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 vulnerable to U.S. policy shifts)
• Institutional-grade crypto services (custody, staking, trading)
• Regulatory clarity in crypto-forward jurisdictions
• Access to international customer base

Disadvantages:

• High minimums and fees ($500K-$2M initial, $5K-$25K monthly)
• Extended timelines (12-20 weeks)
• Requires foreign entity (subsidiary or parent company)
• Complex tax and reporting obligations
• Time zone and language challenges (somewhat mitigated in UK/Singapore)

Recommended Strategy: U.S. companies with international ambitions should establish Swiss or Singapore entities 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. Having a response plan is critical.

Immediate Actions (Day 1-7)

1. Request Written Explanation

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

2. Secure Access to Funds

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

3. Notify Key Stakeholders

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

4. Activate Backup Banking

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

5. File SAR Review Request (if appropriate)

• If closure resulted from SAR filing, you can request FinCEN review (though unlikely to reverse)
• Work with legal counsel to evaluate appeal options
• Document your compliance efforts for future applications

Short-Term Response (Week 2-4)

6. Conduct Internal Investigation

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

7. Remediate Compliance Gaps

• Update AML compliance manual based on findings
• Enhance transaction monitoring procedures
• Implement additional controls
• Document all improvements (critical for 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 exhausted
• Be transparent about prior closure (banks will discover it anyway)

9. Communicate with Customers (if applicable)

• Notify customers of potential temporary service disruptions
• Provide updated payment instructions
• Reassure customers that funds remain secure
• Consider temporary suspension of new customer onboarding until banking stabilized

Long-Term Strategy (Month 2+)

10. Rebuild Banking Relationships

• Work with legal counsel to craft narrative about prior closure
• Emphasize compliance improvements implemented
• Provide third-party audit results confirming enhanced controls
• Target banks with existing crypto expertise (more likely to understand industry challenges)

11. Diversify Banking Infrastructure

• Never again rely on single banking relationship
• Implement 3-4 banking relationships with staged reserves
• Increase stablecoin reserve allocation (30-40% of operating reserves)
• Consider international banking for critical redundancy

12. Consider Strategic Alternatives

• Evaluate merger or acquisition by 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 (Blockchain Association, Chamber of Digital Commerce)
• Build relationships with regulatory officials before 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 Strategic Advantage

In 2025, the crypto companies that succeed are those that treat banking relationships as a strategic asset requiring continuous investment, not a commodity service to be taken for granted.

The companies I represent that have maintained uninterrupted banking access share common characteristics:

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

Banking challenges remain the single most significant operational risk for crypto companies. But with thoughtful planning, robust compliance, and strategic diversification, banking obstacles can be navigated successfully.

The regulatory environment is slowly improving. The OCC's March 2025 clarifications signal a potential thaw in crypto banking access. But even in more favorable regulatory climates, 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. Coinbase CLO, "FDIC resists transparency on Operation Chokepoint 2.0," Cointelegraph (Dec. 2024), available at https://cointelegraph.com/news/fdic-transparency-operation-chokepoint-coinbase-clo; "Proof of Operation Chokepoint 2.0," CoinDesk (Dec. 6, 2024), available at https://www.coindesk.com/opinion/2024/12/06/proof-of-operation-chokepoint-2-0 ↩

2. "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/ ↩

3. "OCC lays out crypto banking after Trump vows to end Operation Chokepoint 2.0," Cointelegraph (Mar. 2025), available at https://cointelegraph.com/news/occ-crypto-banking-donald-trump-ends-operation-chokepoint-2-0 ↩

4. "Operation Chokepoint 2.0 Is Not Dead," Bitcoin Ethereum News (2025), available at https://bitcoinethereumnews.com/tech/operation-chokepoint-2-0-is-not-dead/ ↩

5. "Business Banking for Crypto Companies | Mercury," available at https://mercury.com/web3; "The Best Crypto-Friendly Banks in 2025: A Global Overview," Ulam Labs, available at https://www.ulam.io/blog/the-best-crypto-friendly-banks-worldwide ↩

6. "Top 10 Crypto-Friendly Banks Around the Globe in 2025," B2BinPay (2025), available at https://b2binpay.com/en/news/top-10-crypto-friendly-banks-around-the-globe-in-2024 ↩

7. Financial Action Task Force (FATF), "High-Risk Jurisdictions subject to a Call for Action and Jurisdictions under Increased Monitoring" (updated October 2024), available at https://www.fatf-gafi.org/en/publications/High-risk-and-other-monitored-jurisdictions.html ↩