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The Office of the Comptroller of the Currency (OCC) says nine large national banks used policies that restricted cryptocurrency customers between 2020 and September 2025. The restrictions were not identical: they ranged from outright prohibitions to enhanced reviews and extra approvals. A new OCC/Federal Deposit Insurance Corporation (FDIC) rule now says banks must distinguish genuine financial, operational, money-laundering and sanctions risks from generalized concerns about public reputation.
Which nine banks did the OCC review?
The OCC’s findings, released October 14, 2026, cover historical customer-access policies at these institutions:
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| Bank | Period covered | Individual restriction detail in the published findings |
|---|---|---|
| JPMorgan Chase Bank | 2020–September 2025 | Not specified at bank level in the findings summary |
| Bank of America | 2020–September 2025 | Not specified at bank level in the findings summary |
| Citibank | 2020–September 2025 | Not specified at bank level in the findings summary |
| Wells Fargo Bank | 2020–September 2025 | Not specified at bank level in the findings summary |
| U.S. Bank | 2020–September 2025 | Not specified at bank level in the findings summary |
| Capital One | 2020–September 2025 | Not specified at bank level in the findings summary |
| PNC Bank | 2020–September 2025 | Not specified at bank level in the findings summary |
| TD Bank | 2020–September 2025 | Not specified at bank level in the findings summary |
| BMO Bank | 2020–September 2025 | Not specified at bank level in the findings summary |
The review was unusually large. The OCC examined nearly 100,000 complaints and approximately 50,000 documents totaling about 420,000 pages.
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“Blocked” did not mean the same thing at every bank
The findings describe a spectrum of treatment. Some policies categorically prohibited particular cryptocurrency-related relationships. Others required additional reviews, senior approvals or other hurdles before an account could be opened or maintained. The summary does not assign one of those categories to each individual bank, so it would be inaccurate to say that all nine imposed a blanket ban on every crypto business.
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Why did banks restrict crypto customers?
Many institutions cited concerns about financial crime. Cryptocurrency businesses can involve rapid cross-border transfers, complex ownership structures, sanctions exposure and transaction patterns that are difficult for a bank to monitor. Those are legitimate subjects for a bank’s risk assessment when applied to a specific customer and supported by evidence.
The regulatory issue is the difference between a documented, customer-specific risk decision and a generalized refusal to serve a lawful line of business. The OCC’s current position emphasizes objective, risk-based and case-by-case decisions. A bank may still decline an individual customer, but the rationale should relate to identifiable financial, operational, anti-money-laundering or sanctions risk rather than a broad assumption that all crypto activity is unacceptable.
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What the new OCC/FDIC debanking rule changes
The OCC and FDIC issued their final reputation-risk rule on April 7, 2026, and it became effective June 9, 2026. Its central distinction is that concern about how the public might perceive a customer is not the same as a problem with the bank’s financial condition or its ability to operate safely and soundly.
- Reputation is not a substitute for risk analysis. A bank should not treat anticipated criticism or political pressure, by itself, as proof that a lawful customer presents unacceptable risk.
- Existing safeguards remain. The rule preserves enforcement of the Bank Secrecy Act. Banks must continue to maintain appropriate anti-money-laundering controls, customer due diligence and transaction monitoring.
- Sanctions remain a hard boundary. The account-relationship provision excludes people, entities and jurisdictions subject to sanctions administered by the Office of Foreign Assets Control (OFAC).
- Decisions remain possible. The rule does not create a right to an account. Banks can refuse or end a relationship when they identify objective, supportable risk or cannot manage the relationship within their legal and operational controls.
What the rule does not promise
There is no automatic reinstatement for an account previously closed, no requirement that every bank serve every digital-asset company, and no guarantee that a company with a crypto license will pass a bank’s review. The practical change is the standard for explaining and defending a decision: generalized reputational disapproval is weaker than a documented, customer-specific risk finding.
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Can a crypto company still get a bank account?
Yes, but approval remains discretionary and depends on whether a bank can understand and control the company’s risks. A firm seeking an account should make the bank’s review easier by preparing evidence rather than relying on the fact that its business is lawful.
- Describe the business precisely. Explain whether the company is an exchange, broker, custodian, payment provider, token issuer, mining operation or another type of business. Separate activities that create different transaction and custody risks.
- Document licensing and ownership. Provide applicable state or federal registrations, beneficial-owner information, jurisdictions served and any regulatory examinations or enforcement history.
- Show the anti-money-laundering program. Give the bank written policies, customer-identification procedures, escalation rules, suspicious-activity reporting controls and records showing that the program operates in practice.
- Explain sanctions controls. Describe screening of customers, wallets, counterparties and jurisdictions, how alerts are investigated, and who can stop a transaction when a potential match appears.
- Bring transaction-level transparency. Supply expected volumes, counterparties, payment flows, source-of-funds information and an explanation for unusually large or cross-border activity.
- Set an escalation path. Ask which documents are missing, who owns the review, how an adverse decision can be appealed and whether a periodic reassessment is available. Keep written records of the answers.
None of these steps guarantees an account. They give a bank a record on which it can make the objective, customer-specific judgment the new framework favors.
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What BNY’s USDC service means for crypto firms
BNY announced institutional USDC services on June 29, 2026. The service includes holding USDC in custody and instructing Circle to mint USDC from dollars or redeem USDC for dollars. That links traditional-dollar banking functions with a major stablecoin workflow for eligible institutional customers.
Why smaller businesses should be cautious
BNY’s announcement does not establish that smaller exchanges, payment companies or token issuers can obtain the same arrangement. The available information leaves that question unresolved. Institutional custody and mint/redeem access may involve onboarding standards, risk limits and client eligibility rules that are not available to every business.
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The announcement is therefore evidence that regulated banks can provide narrowly defined digital-asset services, not proof that the broader banking-access problem is solved. A smaller firm still has to pass a bank’s own compliance and risk review.
How to evaluate a bank’s decision
When a bank restricts or closes a crypto account, ask four practical questions:
- Was the decision based on a specific customer, product, transaction pattern or jurisdiction?
- Did the bank identify an anti-money-laundering, sanctions, financial or operational risk that it could not manage?
- Was the same standard applied consistently to comparable customers?
- Is there a documented complaint, appeal or licensing-review route?
A refusal supported by concrete facts is different from a statement that the bank does not serve crypto businesses under any circumstances. The OCC findings and the 2026 rule put that distinction at the center of future supervisory scrutiny, while preserving banks’ responsibility to prevent money laundering and sanctions violations.
The bottom line
Nine major national banks were found to have restricted crypto-related customers in varying ways during 2020–September 2025. The new OCC/FDIC rule does not force banks to accept every crypto company, but it pushes them away from blanket reputational exclusions and toward documented, risk-based decisions. BNY’s USDC offering shows that institutional crypto banking is possible; it does not yet show that comparable access is available to smaller firms.
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