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Clear out junk files and repair common Windows errorsFree Scan →Fix the driver behind crashes, sound loss and screen glitchesFind Drivers →The Office of the Comptroller of the Currency (OCC) says nine large national banks used crypto-account policies between 2020 and September 2025 that ranged from outright prohibitions to extra reviews and approvals. A new OCC/FDIC reputation-risk rule now says banks should not reject lawful businesses merely because of generalized public-perception concerns. It does not create a right to an account: banks may still make objective, risk-based, customer-specific decisions, enforce Bank Secrecy Act requirements and refuse relationships involving people, entities or jurisdictions sanctioned by the Office of Foreign Assets Control (OFAC).
Which nine banks were covered?
The OCC’s October 14, 2026 findings examined customer-access policies at:
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- JPMorgan Chase Bank
- Bank of America
- Citibank
- Wells Fargo Bank
- U.S. Bank
- Capital One
- PNC Bank
- TD Bank
- BMO Bank
The review covered policies in effect from 2020 through September 2025. The published findings describe the group in aggregate; they do not assign a specific prohibition or review requirement to each bank in the summary available here.
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What the OCC found about crypto access
The inquiry examined nearly 100,000 complaints and approximately 50,000 documents totaling about 420,000 pages, according to the OCC’s 2026 findings. The material showed a spectrum of practices:
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- Categorical restrictions: some policies barred relationships with crypto-related businesses or activities.
- Enhanced review: other policies required additional approvals, diligence or monitoring before an account could be opened or maintained.
- Financial-crime explanations: institutions frequently cited money-laundering, sanctions and related financial-crime risks.
The OCC’s current supervisory approach favors documented, objective and risk-based decisions made for the particular customer and activity. That is different from treating an entire lawful industry as unacceptable without examining its controls, licenses, ownership, transaction flows and exposure to prohibited activity.
What the new reputation-risk rule changes
The OCC/FDIC final reputation-risk rule was issued April 7 and became effective June 9. Its central distinction is between a bank’s actual financial or operational condition and concerns about how the public might react to a customer or product. Public-perception concerns, standing alone, are not a substitute for a customer-specific risk analysis.
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| Issue | What the historical review found | What the rule means now |
|---|---|---|
| Industry-wide crypto bans | Policies across the nine-bank group ranged from categorical prohibitions to enhanced review. | A bank should be able to explain a restriction with objective, risk-based reasons tied to the relationship, rather than generalized disapproval of lawful crypto activity. |
| Reputation concerns | Public-perception considerations appeared among the reasons used to limit access. | Reputation risk is treated as distinct from the bank’s financial or operational condition and cannot replace evidence-based risk management. |
| Anti-money-laundering controls | Financial-crime concerns were frequently cited. | The rule preserves Bank Secrecy Act enforcement. Banks must still identify and manage money-laundering and related risks. |
| Sanctions | The historical findings do not eliminate sanctions obligations. | The account-relationship provision excludes OFAC-sanctioned persons, entities and jurisdictions. |
| Account approval | Some customers faced additional approvals or reviews. | The rule does not require a bank to accept every applicant. Individual, documented decisions remain permissible. |
In practical terms, the rule narrows the justification a bank can rely on; it does not turn a bank account into a guaranteed entitlement for a crypto company.
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Yes, a lawful crypto business can still apply, but approval depends on the bank’s assessment of that particular relationship. The strongest application is one that lets a reviewer verify who owns the company, what services it provides, where money comes from and how prohibited transactions are prevented.
- Describe the business precisely. Identify whether the company operates an exchange, custody service, payment product, software platform, brokerage or another activity. Separate customer funds from operating funds and explain every expected payment flow.
- Document licensing and registration. Provide applicable state or federal registrations, money-services-business information and permissions for each jurisdiction in which the company operates. Explain any pending application rather than leaving a gap in the file.
- Show the compliance program. Give the bank written customer-identification, beneficial-ownership, transaction-monitoring, sanctions-screening and suspicious-activity escalation procedures. Describe who is accountable and how often controls are tested.
- Map counterparties and geography. List payment processors, custodians, liquidity providers and major customer regions. Identify exposure to sanctioned jurisdictions, mixers, privacy-enhancing services or other high-risk channels and explain the controls applied.
- Prepare financial and operational evidence. Supply audited or management financial statements, projected volumes, reserve information where relevant, cybersecurity controls and a business-continuity plan. A bank needs to understand both expected activity and the consequences of a failed control.
- Ask how decisions can be reviewed. Request the bank’s onboarding, escalation and complaint contacts in writing. If an application is declined, seek the specific category of concern and provide targeted evidence rather than resubmitting the same general materials.
Monitoring or sanctions software may help a firm document objective controls, but using software does not guarantee approval. The bank remains responsible for deciding whether the relationship fits its risk appetite and legal obligations.
Does BNY’s USDC service solve access for smaller firms?
BNY announced institutional USDC services on June 29, 2026. The service allows institutional clients to hold USDC in custody and to instruct Circle to mint USDC from dollars or redeem USDC for dollars. Those functions can make dollar-to-stablecoin settlement easier for institutions already accepted by the bank.
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The announcement does not establish that smaller crypto businesses can obtain the same arrangement. Eligibility, onboarding standards and the range of customers served are not resolved by the announcement summarized here. A smaller firm should therefore treat the service as an institutional capability, not as evidence that a broadly available crypto checking account now exists.
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- Bank-specific explanations: the OCC’s aggregate findings do not publicly classify each of the nine banks’ policies in the summary available here. Applicants still need to ask each institution how it evaluates crypto relationships.
- Evidence of case-by-case review: a bank that cites a particular product, geography, transaction pattern or control weakness is applying a different standard from a blanket industry exclusion.
- Regulatory boundaries: the new rule does not weaken Bank Secrecy Act enforcement or permit relationships involving OFAC-sanctioned persons, entities or jurisdictions.
- Access beyond deposits: custody, payment rails and stablecoin minting or redemption may be offered separately from ordinary operating accounts, with different eligibility requirements.
The immediate change is accountability for the reason given when access is denied. Crypto firms can still be rejected, but a lawful business should expect the decision to rest on identifiable, defensible risks rather than a conclusory statement that the industry is unpopular.
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