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The nine banks examined by the Office of the Comptroller of the Currency (OCC) are JPMorgan Chase Bank, Bank of America, Citibank, Wells Fargo Bank, U.S. Bank, Capital One, PNC Bank, TD Bank and BMO Bank. OCC findings released October 14, 2026, show that their policies between 2020 and September 2025 ranged from outright crypto prohibitions to enhanced reviews and special approvals.
New OCC/FDIC rules on reputation risk push banks toward objective, customer-specific and risk-based decisions. They do not create a right to a bank account, but they make generalized rejection of a lawful crypto business harder to justify. Crypto companies still need to prove that their anti-money-laundering, sanctions and operational controls are credible.
Which nine banks were examined?
The OCC’s review covered these large national banks and their historical customer-access policies:
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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 examined practices in place from 2020 through September 2025. It did not establish that every one of the nine institutions applied an identical blanket ban to every crypto customer. Instead, the OCC found a range of approaches, including categorical prohibitions, extra scrutiny and approval requirements.
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What the OCC found in its 2026 review
The scale of the inquiry is unusually large. The OCC said it reviewed nearly 100,000 complaints, approximately 50,000 documents and about 420,000 pages. Those materials covered how banks decided whether to provide or continue services to customers connected with cryptocurrency.
Policies varied from bans to enhanced review
Some policies treated crypto activity as categorically unacceptable. Others required additional due diligence, senior approval or ongoing monitoring before an account could be opened or kept. The distinction matters: a case-by-case review can consider a firm’s actual risk profile, while a blanket prohibition rejects the business category before that analysis occurs.
Why banks restricted crypto customers
Many institutions cited financial-crime concerns. Those concerns can include money-laundering exposure, sanctions risk, fraud, rapid movement of funds and difficulties understanding a customer’s transaction flows. The OCC’s current approach does not remove those obligations. It emphasizes that banks should address them with objective, risk-based controls rather than generalized disapproval of a lawful line of business.
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What the new OCC/FDIC reputation-risk rule changes
The OCC/FDIC final reputation-risk rule was issued April 7 and became effective June 9. Its central change is legal and supervisory: a bank’s concern about public perception is treated as distinct from the bank’s own financial condition or operational safety.
Reputation concerns cannot substitute for a customer-specific risk analysis
A bank may still decide that a particular customer presents unacceptable credit, compliance, fraud or operational risk. The rule makes it more difficult to rely on an undefined fear that serving an entire lawful industry could look bad. Decisions should be tied to identifiable facts about the customer, its activities and the controls it operates.
Bank Secrecy Act duties remain in force
The rule does not weaken Bank Secrecy Act enforcement. Banks must continue to maintain customer-identification, transaction-monitoring, suspicious-activity reporting and related compliance programs. A crypto firm that cannot explain its source of funds, beneficial owners, counterparties or monitoring process can still be rejected for concrete risk reasons.
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Sanctions remain an explicit boundary
The account-relationship provision excludes persons, entities and jurisdictions sanctioned by the Office of Foreign Assets Control. The rule therefore should not be read as opening accounts for an OFAC-sanctioned customer or prohibited geography.
Can a crypto company still get a bank account?
Yes, a crypto company can still seek banking services, but the new rule is not an approval guarantee and does not require a bank to accept every applicant. The practical question is whether the company can demonstrate manageable, documented risk.
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A credible application should let a bank test the firm’s controls rather than guess at them. Include:
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- Corporate ownership, beneficial-owner identities and management responsibilities.
- Licenses, registrations and the jurisdictions in which the company operates.
- A plain-language description of products, customers, tokens, wallets and payment flows.
- Written anti-money-laundering and sanctions policies, including escalation and account-closure procedures.
- Transaction-monitoring coverage, alert handling, suspicious-activity reporting responsibilities and independent testing.
- Source-of-funds and source-of-wealth procedures for customers and counterparties.
- Controls for blockchain analytics, mixers, darknet exposure, ransomware proceeds and sanctioned addresses where relevant to the business model.
- Business-continuity, cybersecurity and operational-resilience documentation.
Screening and transaction-monitoring software can help document objective controls, but no software product guarantees account approval. The bank remains responsible for its own risk decision.
Ask how the decision can be reviewed
When a bank declines an application or proposes closure, request the specific risk category, the documents it needs and the available escalation or complaint route. A customer-specific process gives a firm a chance to correct an incomplete file. It also creates a record showing whether the decision rested on measurable risk or an unexplained industry-wide policy.
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Those functions demonstrate that regulated banking infrastructure can support institutional stablecoin activity. They do not establish that a smaller exchange, payments company, wallet provider or other crypto business can obtain the same access. The announcement leaves smaller firms’ eligibility, pricing, onboarding requirements and risk thresholds unresolved.
Why the distinction matters for smaller firms
Large institutions may have the compliance staff, audited controls and established relationships needed for a specialized service. A smaller company may still face intensive onboarding, limits on transaction types or a refusal despite operating lawfully. The OCC rule strengthens the argument for an individualized review, but it does not remove capacity, concentration, liquidity or compliance concerns from a bank’s decision.
How the landscape changes for banks and crypto firms
| Issue | Historical approach examined by the OCC | Direction under the new rule |
|---|---|---|
| Industry-wide treatment | Some policies imposed categorical restrictions on crypto-related customers. | Risk decisions should be tied to objective facts about the customer and activity. |
| Enhanced review | Some customers faced additional reviews or approval requirements. | Enhanced due diligence remains available when the documented risk warrants it. |
| Financial-crime controls | Banks cited money-laundering and related concerns. | Bank Secrecy Act and sanctions obligations continue unchanged. |
| Reputation | Public-perception concerns could influence access decisions. | Reputation risk is treated separately from a bank’s financial or operational condition. |
| Sanctioned parties | Not eligible for the rule’s account-relationship protection. | OFAC-sanctioned persons, entities and jurisdictions remain excluded. |
| Stablecoin services | Comparable services were not established for smaller firms. | BNY’s USDC announcement confirms an institutional model, not universal access. |
What remains unresolved
The OCC findings do not publish a bank-by-bank map showing which of the nine institutions used a categorical ban, enhanced review or another policy in every circumstance. They also do not establish that the new rule will produce uniform approvals, identical appeal procedures or comparable stablecoin services across banks.
For crypto companies, the immediate test is therefore practical: can the firm present a transparent ownership structure, lawful operations and controls that let a bank measure its exposure? For banks, the test is whether an adverse decision can be explained through documented financial, operational, compliance or sanctions risk rather than a generalized objection to crypto.
