A crypto company’s bank partnership is not proof that the company is safe, that your crypto is a bank deposit, or that a regulator has endorsed the arrangement. To evaluate the relationship, trace who holds and owes each kind of money, verify the company’s authority and controls, examine the bank’s oversight and contingency plans, and read the customer disclosures that govern your account.
This is a U.S.-focused framework for assessing a crypto business, its banking arrangements, or what the arrangement means for your money. It is not a company-specific investment assessment or legal opinion. Confirm current company facts in filings, regulator records, contracts, and the account documents that apply to you.
Start by mapping the service, entities, and money
“Bank partner” is a broad label, not a description of who does what. Follow the customer journey and identify the legal entity responsible at each step. Separate bank deposits from crypto assets and other claims: the party that displays a balance in an app may not be the bank or the party that owes you that balance.
- Who is the customer’s contractual counterparty, and which entity owes repayment or delivery?
- Which insured bank, if any, holds a deposit, and in whose name is the account?
- Who can receive, move, or freeze funds?
- Which parties provide custody, payment processing, settlement, customer support, data handling, or technology?
- What happens to each function if the crypto company, bank, or another service provider stops operating?
The agencies’ third-party relationship guidance calls for banks to understand the activities performed through third parties and assess risk throughout the relationship. The 2023 interagency guidance and the Federal Reserve’s 2024 fintech due-diligence guide for community banks are useful reference points for understanding the bank’s role; they are not a substitute for examining the specific arrangement.
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Check whether the company is legally equipped to provide the service
Verify the company’s full legal identity, beneficial owners, jurisdictions, and authority to perform the activities it actually offers. The relevant licenses or registrations depend on the service and geography; a partnership announcement alone does not establish that the company has every required authorization.
- Check regulator records for applicable licenses, registrations, enforcement actions, and public statements.
- Review litigation, sanctions exposure, and the company’s history of responding to regulators.
- Ask what compliance systems and expertise support the service, how issues are escalated, and how the company addresses potential consumer harm.
- Look for clear accountability: who owns compliance decisions, and how are duties separated so one person or team cannot improperly control every step?
The interagency guidance identifies ownership, legal authority, sanctions, compliance processes, regulatory responsiveness, and consumer-harm mitigation as due-diligence considerations. They are useful lines of inquiry, not a universal pass/fail checklist.
Assess financial capacity, controls, and continuity
A durable relationship requires more than a bank willing to provide a service. Assess whether the crypto company can meet its obligations and keep the service running, and whether its controls are tested and problems corrected.
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- Financial condition: Review audited financial information and, where applicable, regulatory or securities filings. Consider funding, liquidity, liabilities, litigation, growth assumptions, and dependence on a single bank relationship.
- People and governance: Examine relevant experience, staffing, key-person qualifications and succession, board or management oversight, and responsibility for risk decisions.
- Technology and security: Ask about security controls, incident response, subcontractors, independent testing, and the scope and date of any audit or controls report. An audit’s existence does not show that it covers every service or current risk.
- Issue management: Look for findings, remediation deadlines, escalation paths, and evidence that recurring problems are addressed rather than merely documented.
For the bank-side arrangement, look for named relationship owners, ongoing monitoring, performance measures, audit and access rights, and a way to escalate concerns. The 2024 joint statement on banks’ arrangements with third parties to deliver deposit products and services emphasizes planning for disruption or a third party’s business failure, including the ability to transfer accounts, data, or activities.
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1Repair Windows errors before they cause bigger problems2Fix the driver behind crashes, sound loss and screen glitches3Clear out junk files and repair common Windows errorsDetermine what deposit insurance does—and does not—cover
FDIC insurance applies to deposits held at an FDIC-insured bank, subject to applicable rules and limits. A crypto company’s association with a bank does not turn a crypto asset, or every balance shown by the company, into an insured deposit. The FDIC’s advisory on deposit insurance and dealings with crypto companies warns that customers should receive clear information about what is and is not insured.
Read the account agreement and insurance disclosures, not just a marketing statement. Identify the insured institution, the legal account holder, the type of asset, and the entity that owes you the funds. If the documents do not make those roles clear, ask the company and bank for a precise explanation before relying on an insurance claim.
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Test whether you could access funds after a failure
Consider two separate disruptions: the crypto company becomes unavailable, or the bank or another provider interrupts service. A sound plan should explain how customers and counterparties can identify balances, reconcile records, and continue or transfer the relevant activity.
- How are customer records and bank records reconciled, and who can access them during an outage?
- Who informs customers, and how will they authenticate themselves or make a claim?
- Can accounts, data, or activities be transferred to another provider? Who has the contractual right and practical ability to do so?
- What triggers a transition or termination, and how long could access be disrupted?
The 2024 interagency deposit-services statement specifically highlights contingency planning for disruption or business failure at a third party. A plan that exists only on paper, without access rights, usable records, and workable transfer arrangements, may not preserve customer access.
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Compare customer-facing claims with the contracts
Put the company’s website and app language alongside its account agreement, bank disclosures, statements, custody terms, and applicable service contracts. Check that each document distinguishes the bank, the crypto company, and any other provider—and that it does not imply the crypto company itself is a bank or that all customer funds receive deposit insurance.
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Pay attention to the wording used for balances and custody. A “cash” balance, a bank deposit, a crypto asset, and a contractual claim against a company are not interchangeable descriptions. If the app’s labels or advertising suggest more protection than the account documents establish, treat the difference as an unresolved risk.
Independent reader supportYour contribution helps us test, update, and keep practical guides available for everyone.Read regulatory statements with their dates and scope
Regulatory statements can change, and a statement about one agency’s process should not be generalized to all banks or all crypto activities. On January 3, 2023, the Federal Reserve, FDIC, and OCC issued a joint statement on crypto-asset risks to banking organizations, describing a careful and cautious approach to crypto-related bank exposures at that time.
On March 28, 2025, the FDIC clarified its process for FDIC-supervised institutions: they may engage in permissible crypto-related activities without prior FDIC approval. The clarification does not mean every activity is permissible, does not constitute approval of a particular company, and does not describe every banking regulator’s process. The FDIC also pointed to risks including market and liquidity risk, operational and cybersecurity risk, consumer protection, and anti-money-laundering requirements; institutions should engage with their supervisory teams as appropriate.
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Compare companies using evidence, not the partnership label
If you are assessing more than one company, use the same criteria for each and distinguish verified facts from marketing claims. The following comparison framework synthesizes regulator guidance; it is not a regulator-issued rating system.
| Comparison area | What to establish |
|---|---|
| Structure and money flow | Clarity about entities, services, who holds deposits, who owes customers, and who can move funds. |
| Legal authority and compliance | Relevant authority for the actual service and geography; compliance controls, regulatory history, and issue response. |
| Financial and relationship resilience | Financial capacity and liabilities, plus concentration or dependence on a bank or other provider. |
| Governance and controls | Accountability, independent controls testing, security practices, incident response, and remediation. |
| Customer treatment | Consistency of disclosures and contracts, complaint handling, and clarity about insurance and custody. |
| Oversight and contingency | Bank monitoring, audit and access rights, termination planning, and practical transferability of accounts, data, or activities. |
| Evidence quality | Whether claims are supported by current primary records and documents that cover the specific service. |
For any named company, verify current counterparties, ownership, licenses, financial condition, litigation and enforcement history, control reports, concentration risks, termination terms, customer disclosures, and relevant bank or regulator statements. General principles cannot establish those company-specific facts.
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