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This U.S.-focused framework helps consumers and risk professionals assess a crypto business’s relationship with a bank. It is not an investment rating or legal opinion; company-specific conclusions require current filings, agreements, regulator records, and account documents.
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1. Map the service, entities, and movement of money
Start with the customer journey rather than the phrase “bank partner.” Identify every legal entity and what it does. A company may rely on different organizations for deposit accounts, payment processing, crypto custody, settlement, customer data, or technology. Those roles carry different risks and do not automatically belong to the bank.
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Draw the flow from the customer’s payment or deposit to its destination, and identify who owes the customer money at each stage. Separate bank deposits from crypto assets and other contractual claims. Record who can move the funds, which institution holds any deposit, and what happens if each company or service provider becomes unavailable. Federal banking agencies’ 2023 third-party guidance says banks should understand the specific activities and manage the risks of third-party relationships across their lifecycle: Interagency Guidance on Third-Party Relationships.
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- Which entity receives and holds customer money?
- Which entity is legally responsible for paying the customer back?
- Who controls withdrawals, transfers, custody, and account records?
- Which services depend on subcontractors or other technology providers?
- If one link fails, can customers still access funds or records?
2. Verify what the bank relationship actually means
Find out what the bank does, what the crypto company does, and which entity has the customer relationship. A bank may provide deposit accounts or payment services without operating the crypto company’s platform or guaranteeing its obligations. Do not treat a partner-bank logo or announcement as evidence of the arrangement’s full scope.
The bank retains responsibility for its own obligations when it uses a third party. The Federal Reserve, FDIC, and OCC stated in their May 2024 community-bank due-diligence guide: “Engaging a third party does not diminish or remove a bank’s responsibility to operate in a safe and sound manner and to comply with applicable legal and regulatory requirements, including consumer protection laws and regulations, just as if the bank were to perform the service or activity itself.” The guide describes considerations for bank diligence, not a universal certification of a particular crypto company. Read the guide.
3. Check the company’s legal authority and compliance
Confirm the company’s legal name and corporate identity, beneficial owners, operating jurisdictions, and authority to provide each service it actually offers. Requirements can depend on the activity and geography, so a generic claim that a company is “licensed” is not enough. Check relevant public regulator records, enforcement actions, litigation, sanctions exposure, and the company’s history of responding to regulatory issues.
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Look for evidence that the company can identify, escalate, and fix compliance problems and potential consumer harm. The interagency guidance identifies ownership, legal authority, sanctions, compliance processes, regulatory responsiveness, and consumer-harm mitigation among diligence considerations. It does not prescribe a single pass/fail scorecard.
4. Assess finances, people, and operational controls
A bank relationship does not establish that a crypto company has enough capital, liquidity, staff, or controls to keep operating. Use current audited financial statements and, where applicable, regulatory or securities filings. Consider liabilities, litigation, funding, liquidity, growth assumptions, and dependence on a particular bank or service provider.
Examine the people and systems behind the service as well as its financial position. Ask about relevant experience, staffing, key-person succession, subcontractors, technology and security controls, incident response, and the scope of independent audits or testing. Check whether identified problems were remediated. A partnership announcement is not evidence that these safeguards are effective.
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5. Examine the bank’s oversight and the contract
For the bank-side relationship, look for clear accountability and ongoing supervision rather than a one-time onboarding review. Relevant evidence includes named relationship owners, management and board oversight, documented diligence, performance monitoring, audit and information-access rights, escalation procedures, and enforceable termination or transition terms. The interagency third-party guidance addresses planning, due diligence, contracting, ongoing monitoring, and termination.
For arrangements that deliver bank deposit products or services through third parties, the agencies’ July 2024 joint statement highlights contingency planning for disruption or a provider’s business failure. Review how account information, records, and activities could be transferred, and whether customers could retain access during that transition. Read the joint statement.
6. Determine whether a balance is actually FDIC-insured
A bank partnership alone does not make a crypto balance an insured deposit. The FDIC insures deposits held at insured banks; crypto assets and balances owed by a crypto company do not become bank deposits merely because the company has a bank relationship. Identify the insured institution, the legal account holder, the nature of the asset, and the exact account and insurance disclosures. Read the company’s account agreement and statements rather than relying on marketing language.
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Compare claims in the app and advertising with account agreements, custody terms, statements, and the named entities’ roles. Watch for language that implies the crypto company itself is a bank, that crypto holdings are deposits, or that every customer balance is insured. The FDIC’s advisory to insured institutions emphasizes clear communication about what is and is not covered: FDIC Advisory on Deposit Insurance and Dealings with Crypto Companies.
Independent reader supportYour contribution helps us test, update, and keep practical guides available for everyone.7. Read regulatory statements in context and by date
Regulatory positions and processes can change, and statements from one banking agency should not be generalized to all regulators. On January 3, 2023, the Federal Reserve, FDIC, and OCC issued a joint statement describing their position on crypto-asset risks to banking organizations at that time: Joint Statement on Crypto-Asset Risks to Banking Organizations.
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8. Compare companies using the same evidence standards
If you are comparing multiple businesses, use consistent criteria and record when each piece of evidence was obtained. These are practical comparison axes synthesized from regulator guidance, not an official regulatory rating system.
| Comparison area | What to examine |
|---|---|
| Structure and money flow | Clarity about entities, services, custody, deposit holding, and who owes the customer. |
| Legal authority and compliance | Relevant authority for actual services and locations, compliance controls, sanctions exposure, and regulatory history. |
| Financial resilience | Financial condition, liabilities, liquidity, and dependence on a bank or other provider. |
| Governance and controls | Accountability, independent testing, security practices, incident response, and remediation. |
| Customer treatment | Clear and accurate disclosures, complaint handling, and consistency between marketing and account documents. |
| Bank oversight and continuity | Monitoring, contingency plans, termination terms, and the practical ability to transfer accounts, records, or activities. |
| Evidence quality and recency | Whether claims are supported by current primary records, contracts, filings, and regulator information. |
What to request for a company-specific assessment
A general framework cannot establish the current safety or insurance status of a named crypto company. To reach a company-specific view, verify its beneficial ownership, bank counterparties, service and deposit structure, relevant licenses or registrations, financial condition, litigation and enforcement history, control reports, concentration risks, contract termination terms, customer disclosures, and any statements from the bank or regulators. Use current primary documents wherever possible.
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