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A crypto company can seek banking services without holding its own national trust bank charter. Its main options are to apply directly to an existing bank, work through a bank–third-party arrangement, or assess state-chartered or state-licensed routes that fit its activities. The right choice depends on what the company does, how money moves, and where it operates; no bank is required to accept a particular crypto business.
What banking options can a crypto company use?
| Route | What it can provide | Key distinction |
|---|---|---|
| Direct relationship with an existing bank | Business deposits, treasury, payment, or other bank services | The company applies to a bank; acceptance and available services are institution-specific. |
| Bank–third-party arrangement | A bank-provided deposit product, with a crypto company potentially supplying technology, distribution, or customer-facing services | The bank holds the deposit product and retains oversight responsibilities for its third-party relationship. |
| State-chartered or state-licensed structure | Depending on the state and business model, a trust or bank charter, or a license such as money transmission | Requirements depend on activities, custody, customer-funds flows, and jurisdictions; these routes are not interchangeable. |
| National trust bank charter | Trust-company operations and related activities within the charter’s scope | A separate federal route; it is not synonymous with an insured, full-service commercial bank charter. |
Can a crypto company get a bank account without its own charter?
Yes. A company can apply to an existing bank for business deposit and payment services without owning a national trust bank charter. The practical question is whether a particular institution is willing and legally able to serve the company’s specific activities. Regulatory permission for banks to engage in some crypto-related activities does not require any bank to take on any particular customer.
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Describe the company’s business accurately when approaching banks. Its product, custody model, customer-funds flows, jurisdictions, and compliance controls can affect which services a bank is prepared to offer. A request for operating deposits, for example, is not the same as a request for custody or stablecoin-reserve services.
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How does a bank–third-party arrangement work?
In a bank–third-party arrangement, an insured bank may provide the deposit product while a crypto company supplies technology, distribution, or customer-facing services under contract. The arrangement does not make the crypto company a bank. The agencies’ 2024 joint statement on bank relationships with third parties emphasizes that banks should manage the risks and oversee these arrangements appropriately.
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For customers and counterparties, the important details are which bank holds the deposit, what role the crypto company plays, and how the account is legally structured. Those details also matter when describing deposit insurance; a bank relationship alone does not mean that a customer’s crypto balance is an insured deposit.
When should a company consider a state charter or license?
A state trust-company or bank charter, or a license such as money transmission where applicable, may be relevant to a company’s business model. These are distinct legal routes, not substitutes that automatically fit every crypto company. The analysis can turn on the state, the activities performed, whether the company takes custody, and how customer money moves.
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Because requirements vary by activity and location, a company should map its services and funds flows against the jurisdictions where it operates before settling on a state route. The available information here does not determine any particular company’s state obligations.
What does a national trust bank charter authorize?
A national trust bank charter is a federal charter for trust-company operations and related activities; it should not be described as a regular, full-service commercial bank charter or as proof that an institution offers insured deposits. In a rule effective April 1, 2026, the Office of the Comptroller of the Currency (OCC) clarified that covered national banks limited to trust-company operations and related activities may conduct non-fiduciary as well as fiduciary activities within the charter’s statutory scope. The institution’s actual authority still depends on its charter and OCC decisions.
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An application or conditional approval is not the same as final authority to operate or evidence that a company is already offering banking services. Check the institution’s status and approved activities rather than inferring them from the type of charter it has sought.
What did federal agencies change in 2025?
- March 7, 2025 — OCC: Interpretive Letter 1183 reaffirmed that national banks and federal savings associations may engage in crypto-asset custody, hold deposits serving as stablecoin reserves, and use distributed ledger technology and stablecoins for permissible payment activities. It rescinded the supervisory non-objection process in Interpretive Letter 1179; Letters 1170, 1172, and 1174 remained in effect.
- March 28, 2025 — FDIC: The agency said FDIC-supervised institutions may engage in permissible crypto-related activities without prior FDIC approval if they adequately manage associated risks.
- April 24, 2025 — Federal Reserve: The Fed withdrew its advance-notification expectation for state member banks’ crypto-asset activities and said it would monitor those activities through normal supervision.
- May 7, 2025 — OCC: Interpretive Letter 1184 said national banks and federal savings associations may buy and sell assets held in custody at customers’ direction and outsource bank-permissible crypto activities, including custody and execution, subject to appropriate third-party risk management and applicable law.
These changes address how supervised banks may conduct permissible activities; they do not guarantee a crypto company an account or remove banks’ safety-and-soundness, legal-compliance, and risk-management obligations. As Acting Comptroller Rodney E. Hood put it in the OCC’s March 7, 2025 release: “The OCC expects banks to have the same strong risk management controls in place to support novel bank activities as they do for traditional ones.”
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Are crypto company or exchange balances FDIC-insured?
FDIC insurance applies to qualifying deposits held at insured banks and savings associations. It does not insure crypto-assets issued by non-bank crypto companies. Do not describe crypto as “FDIC-insured” merely because a company has a bank partner.
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How should a company compare its options?
- Specify the service needed. Separate operating deposits and payments from custody, settlement, or stablecoin-reserve custody; one banking relationship may not address every need.
- Map the funds flow. Identify who receives, holds, transfers, and controls customer or company funds, and which institution legally holds any deposits.
- Match the route to the activity and location. Compare direct bank service, a bank–third-party arrangement, and applicable state or federal routes against the company’s actual services and operating jurisdictions.
- Verify status and responsibilities. Confirm the bank or chartered institution’s authority, any relevant approval status, the crypto company’s role, and the compliance and oversight obligations attached to the arrangement.
- Assess operational resilience. Consider governance, compliance, operational continuity, and concentration in a bank or other counterparty as part of the choice.
This is a U.S.-focused overview, not an individualized licensing determination. A company-specific answer requires its product details, funds flows, and operating locations.
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