Yes. U.S. banks do not need the CLARITY Act to serve every crypto company. A bank may provide services when the specific activity is permitted under applicable federal and state law and the bank can manage its risks. Recent law and agency actions clarify some authority and supervisory processes, but they neither approve every crypto business model nor require a bank to accept a particular customer.
Does a crypto company need the CLARITY Act to get a bank account?
No. The CLARITY Act is a proposed market-structure bill, not a general prerequisite for a crypto company to open a bank account. H.R. 3633, the Digital Asset Market Clarity Act of 2025, would establish a framework for digital commodities and SEC and CFTC roles, among other provisions. House materials record consideration and passage events in July 2025. The sources available here do not establish its Senate status as of October 4, 2026, so it should not be described as enacted or as definitively stalled.
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An account relationship is distinct from permission to conduct a particular financial activity. Whether a bank can serve a firm depends on what services the firm needs, the bank’s charter and applicable law, and whether the bank can manage the resulting risks.
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The GENIUS Act became Public Law 119-27 in July 2025. At 12 U.S.C. § 5915, it says the chapter does not limit a depository institution, credit union, national bank, or trust company from conducting activities otherwise permissible under applicable state and federal law.
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The statute gives examples: taking deposits; using distributed-ledger technology for the institution’s records and intrabank transfers; and providing custody of payment stablecoins, private keys, or stablecoin reserves. The key qualification is that the activity must already be permissible under other applicable law. This is not blanket approval for every digital-asset service or business model.
What changed for banks under the OCC and FDIC in 2025?
The agencies addressed different groups of institutions and different supervisory processes. Removing or clarifying a prior-notification step does not remove the bank’s continuing legal and safety obligations.
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| Agency and date | Institutions addressed | What changed or was clarified | What remains |
|---|---|---|---|
| OCC, March 7, 2025 | National banks and federal savings associations | Interpretive Letter 1183 reaffirmed that they may provide crypto-asset custody, engage in certain stablecoin activities, and participate in independent node verification networks. | Activities remain subject to applicable law and risk controls. |
| FDIC, March 28, 2025 | FDIC-supervised institutions | The FDIC rescinded FIL-16-2022, ending its prior-notification requirement for permissible crypto-related activities. The FDIC said these institutions may conduct such activities without prior FDIC approval if they adequately manage associated risks. | Only permissible activities are covered; risk management and supervision continue. |
Does permission mean a bank must accept a crypto customer?
No. These authorities are permissive: they describe activities a bank may conduct when legal and supervisory conditions are met. They do not give an individual crypto company a right to an account or require a bank to onboard it. A bank makes its own institution-specific decision within the law and under its supervisory obligations.
Why do custody and stablecoin services still require controls?
Legal authority does not eliminate operational, compliance, or safety-and-soundness responsibilities. An OCC bulletin in May 2025 reported a joint statement from the OCC, Federal Reserve Board, and FDIC on crypto-asset safekeeping. It underscores that custody requires risk-management controls and continued supervisory attention.
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The FDIC also approved a proposed rule on April 7, 2026, addressing GENIUS Act standards for permitted payment-stablecoin issuers and insured depository institutions, reserve deposits, deposit-insurance treatment, and tokenized deposits. It was a proposal, not a final rule; it should not be treated as a completed regulatory framework.
Independent reader supportYour contribution helps us test, update, and keep practical guides available for everyone.What should a crypto company clarify with a prospective bank?
The practical answer depends on the requested service, not simply on whether the applicant calls itself a crypto company. Be specific about the activity and its structure:
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- Ordinary deposit account: Explain the company’s business, expected funds flows, counterparties, and the purpose of the account.
- Payment stablecoins: Distinguish issuance from holding reserves or providing related banking services. The GENIUS Act’s examples concern payment stablecoins and do not settle every digital-asset question.
- Custody or safekeeping: Identify exactly what the bank would hold or safeguard, including whether the service involves assets, private keys, or reserves, and how controls would work.
- Distributed-ledger operations: Distinguish internal recordkeeping or intrabank transfers from other network activities, such as independent node verification.
- Regulatory perimeter: Identify the bank’s charter and relevant federal and state law; the cited agency actions apply to specified institution types and do not resolve every state-law question.
For a U.S. company, the useful question is therefore not simply whether the CLARITY Act has become law. It is whether the specific service is lawful for the bank, under its charter and applicable law, and whether the bank is prepared to manage and supervise the associated risks.
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