A crypto company can seek banking services without holding its own national trust bank charter. It may apply directly to an existing bank, work with a bank that provides deposit services through a third-party arrangement, or assess state-chartered or state-licensed routes that fit its activities. Which option works depends on what the company does, how money moves, and where it operates; no bank is required to accept every crypto business.
Does a crypto company need its own bank charter?
No. A company can apply to an existing bank for business deposits, treasury services, or payments without becoming a bank itself. The bank decides whether to serve the company and must manage the relationship in line with applicable law, safe and sound operations, and its risk controls.
That is different from a crypto company holding a charter in its own name. A bank relationship may meet a business’s operational needs, while a charter is a regulatory route for conducting specified banking or trust activities. A charter application, or conditional approval, does not by itself mean the applicant has final authority to operate or is offering ordinary insured deposits.
What banking options are available?
| Route | How it works | What to establish |
|---|---|---|
| Direct relationship with an existing bank | The company applies to a bank for business deposit, treasury, payment, or other services. | Whether the bank will serve the company’s specific activities, and which services and accounts it will provide. |
| Bank–third-party arrangement | An insured bank provides the deposit product while a crypto company may supply technology, distribution, or customer-facing services under contract. | Which bank holds the deposits, what role the crypto company performs, and how the bank oversees the arrangement. |
| State-chartered or state-licensed structure | The company explores a state trust company or bank charter, or applicable nonbank licenses such as money transmission. | Which requirements apply in each jurisdiction, based on the actual services, custody model, and movement of funds. |
| National trust bank charter | The company seeks a federal charter for trust-company operations and related activities within the charter’s scope. | The charter’s actual authority and operating status; this route is not synonymous with an insured, full-service commercial bank charter. |
Direct bank relationship
This is the most straightforward route to investigate when the need is for company operating accounts or payment and treasury services. Regulatory permission for banks to conduct certain crypto-related activities does not guarantee that a particular institution will accept an applicant. The company should describe its business and funds flows accurately when approaching banks.
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Bank partner
A bank–third-party arrangement can put a bank-provided deposit product within reach of a company that delivers the customer-facing service or technology. The parties’ roles should not be blurred: identify the bank that holds deposits and the crypto company’s contractual role. Federal banking agencies’ 2024 joint statement addresses the risk management and oversight expected for these arrangements.
State charter or license
A state trust company or bank charter and a nonbank license are distinct routes, not interchangeable labels for a national trust bank charter. Whether a license is needed—and which one—depends on the activity, customer-funds model, and states involved. A company-specific determination requires reviewing those details rather than assuming one nationwide answer.
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National trust bank charter
This is a separate federal option for trust-company operations and related activities. An OCC rule that took effect April 1, 2026 clarified that covered national trust banks may conduct non-fiduciary as well as fiduciary activities within the charter’s statutory scope. That clarification does not make every national trust bank a full-service commercial bank or establish that a particular applicant has final operating authority.
What changed in federal policy—and what did not?
In 2025, federal agencies changed certain supervisory procedures for banks’ crypto-related activities. The changes addressed how supervised banks may conduct permissible activities; they did not give crypto companies a right to an account or remove banks’ risk-management and legal obligations.
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- March 7, 2025: The OCC’s 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; Interpretive Letters 1170, 1172, and 1174 remained in effect.
- March 28, 2025: The FDIC said FDIC-supervised institutions may engage in permissible crypto-related activities without prior FDIC approval if they adequately manage the associated risks.
- April 24, 2025: The Federal Reserve withdrew its advance-notification expectation for state member banks’ crypto-asset activities and said it would monitor them through normal supervision.
- May 7, 2025: In Interpretive Letter 1184, the OCC said national banks and federal savings associations may buy and sell assets held in custody at customers’ direction, and outsource bank-permissible crypto activities such as custody and execution, subject to appropriate third-party risk management and applicable law.
These permissions do not mean every bank offers these services, must accept a crypto company, or can disregard safety, soundness, compliance, or risk controls. Nor does a bank’s involvement make crypto assets insured deposits.
Are crypto 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 nonbank companies. A crypto company’s token or customer balance is not insured simply because the company has a bank partner.
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For a custodial, omnibus, or pass-through account, determine which institution legally holds the funds and how the account is structured before making any claim about deposit insurance. The existence of a partner bank alone does not establish that a particular customer balance qualifies for coverage.
Independent reader supportYour contribution helps us test, update, and keep practical guides available for everyone.How should a company compare its routes?
Start with the service the company actually needs, rather than with a charter label. An operating deposit account, payment processing, custody, settlement, and stablecoin-reserve custody raise different questions.
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- Map the activity and funds flow: Identify who receives, holds, transfers, and controls customer or company funds, and whether the product involves custody, payments, or reserve assets.
- Identify the institution and role: For a bank relationship or partner model, establish which bank holds deposits and what the crypto company does under the arrangement.
- Check geography and regulatory scope: Determine where the company operates and which state requirements may apply to its particular activities.
- Assess operational and counterparty risk: Consider governance, compliance, resilience, and reliance on a single banking provider as part of the route-selection process.
- Verify status before relying on a charter: Distinguish an application or conditional approval from final authority and actual operating services.
Because those factors vary by business model and jurisdiction, the available information does not establish one licensing answer for all crypto companies. A company considering a route should have its product, custody arrangements, funds flow, and operating locations reviewed together.
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