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A crypto company’s bank partnership is not proof that the company is safe, that its crypto balances are insured, or that regulators have approved its business. Evaluate the relationship by tracing the service and money flow, checking the company’s legal authority and controls, and verifying what the bank actually provides. For a U.S.-focused assessment, use the steps below as a diligence framework—not as a company-specific investment assessment or legal opinion.
Start by mapping the service, entities, and money flow
“Bank partner” is a broad label. It does not explain which company holds deposits, owes money to customers, processes payments, safeguards crypto assets, handles data, or supplies technology. Map the arrangement from the customer’s point of view, naming each legal entity and its role.
- List the entities involved, including the crypto company, any bank, custodians, payment processors, and significant technology providers.
- Trace what happens when a customer deposits, buys, sells, transfers, or withdraws funds. Identify who receives each asset and who can move it.
- Separate bank deposits from crypto assets and other customer claims. Record which institution holds any deposit and which entity is legally responsible for paying the customer.
- For each step, ask what happens if that company or service stops operating, loses access, or cannot process transactions.
This activity-by-activity approach reflects the 2023 interagency guidance on third-party relationships and the agencies’ May 2024 fintech due-diligence guide.
Does a bank partnership mean customer funds are FDIC insured?
No—not by itself. The FDIC insures deposits held at insured banks; a crypto asset or a balance owed by a crypto company does not become an insured bank deposit just because the company works with a bank. The legal account holder, the insured institution, and whether the particular asset is a deposit all matter.
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Check the account agreement, statements, app disclosures, and custody terms. Determine who holds the account and who owes you the funds. Look for clear, specific language explaining what is insured and what is not; do not rely on a logo, a partnership announcement, or a general statement that customer funds are “held at a bank.” The FDIC’s 2022 advisory on deposit insurance and dealings with crypto companies addresses the need for accurate communication about insurance coverage.
Check the company’s authority, ownership, and compliance
Verify that the company is legally identifiable and authorized to perform the services it offers. Requirements depend on the actual activity and geography, so do not assume that one license or registration covers every product or customer location.
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- Identity and ownership: Confirm the corporate entity, jurisdictions of operation, beneficial owners, and authority to provide each service.
- Regulatory and legal history: Review relevant regulator records, enforcement actions, litigation, sanctions exposure, and responses to past compliance issues.
- Compliance capability: Examine the expertise, systems, and procedures used to identify and address compliance problems and potential consumer harm.
- Accountability: Look at leadership qualifications, governance, responsibility for compliance, and whether duties and approvals are appropriately separated.
The agencies describe these as relevant diligence considerations, not a universal pass/fail scorecard. Their 2024 guide discusses ownership, legal authority, sanctions, compliance processes, regulatory responsiveness, and consumer-harm mitigation.
Assess financial and operational resilience
A partnership announcement says little about whether a company can meet its obligations or keep its service running. Look for evidence appropriate to the company and service, including audited financial information and applicable regulatory or securities filings.
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- Review liabilities, litigation, funding, liquidity, and the company’s ability to continue operating under adverse conditions.
- Assess the experience and staffing behind the service, including key-person succession and reliance on subcontractors.
- Ask what technology, security, and incident-response controls protect transactions, customer information, and assets.
- Check the scope and independence of audits or controls testing, the issues identified, and whether remediation was completed.
For the bank relationship, also consider concentration: how dependent is the crypto company on a single bank or other critical provider, and what alternative arrangements exist? A company can have a legitimate bank relationship while still having financial, control, or continuity weaknesses.
Examine bank oversight, contracts, and customer continuity
The bank’s use of a third party does not transfer away its own regulatory responsibilities. The Federal Reserve, FDIC, and OCC’s May 2024 guide states: “Engaging a third party does not diminish or remove a bank’s responsibility to operate in a safe and sound manner and to comply with applicable legal and regulatory requirements, including consumer protection laws and regulations, just as if the bank were to perform the service or activity itself.”
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Where a third party delivers deposit products or services, the agencies’ July 2024 joint statement makes continuity and customer access important diligence questions. Look for evidence of:
- Named bank-side owners, management and board oversight, ongoing monitoring, and performance measures.
- Contractual audit and information-access rights, clear issue escalation, and a workable termination process.
- Accurate account records and reconciliation between the bank, company, and customer-facing records.
- A realistic plan to transfer accounts, data, or activities if the company fails, the service is disrupted, or the relationship ends.
Ask how customers would learn about a disruption, who would provide support, and how they could access or transfer funds. The existence of a contract or contingency plan is not enough on its own; the relevant question is whether it provides a credible route to continuity and customer access.
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Compare customer-facing claims with the underlying documents
Read marketing and in-app wording alongside bank account agreements, statements, disclosures, and custody terms. Check whether the documents distinguish the bank, the crypto company, and any custodian—and whether they clearly identify what the customer owns and which entity owes payment.
Be cautious when language suggests that the crypto company itself is a bank, that crypto balances are deposits, or that all customer funds are insured. The FDIC’s advisory calls for clear communication about the limits of deposit insurance in dealings involving crypto companies.
How to compare multiple crypto companies
Use the same questions for each company, and distinguish documented evidence from marketing claims. These comparison areas synthesize agency guidance; they are not a regulator-issued rating system.
| Area | What to compare |
|---|---|
| Structure | How clearly the company identifies entities, services, deposit holders, asset custodians, and the flow of customer funds. |
| Authority and compliance | Relevant legal authority, compliance systems, regulatory history, sanctions controls, and handling of consumer harm. |
| Financial condition | Available evidence about liabilities, liquidity, financial capacity, and dependence on a bank or other critical provider. |
| Governance and controls | Oversight, separation of duties, independent testing, incident response, and remediation of identified issues. |
| Customer protection | Clarity of disclosures, complaint handling, account records, and explanations of deposit insurance and custody. |
| Continuity | Bank oversight, contingency planning, termination provisions, and the practical ability to transfer accounts, data, or activities. |
| Evidence quality | Whether claims are supported by relevant documents and whether those documents are current enough for the decision. |
Interpret regulatory statements in their date and scope
Regulatory statements should not be treated as timeless or interchangeable. On January 3, 2023, the Federal Reserve, FDIC, and OCC issued a joint statement on crypto-asset risks to banking organizations, describing the agencies’ position at that time.
On March 28, 2025, the FDIC said that FDIC-supervised institutions may engage in permissible crypto-related activities without prior FDIC approval. The agency also pointed to market and liquidity risk, operational and cybersecurity risks, consumer protection, and anti-money-laundering requirements, and said banks should engage with their supervisory teams as appropriate. This is an FDIC-specific process clarification; it does not mean that every crypto activity is permissible or approved, or establish the process of every banking regulator. See the FDIC’s March 28, 2025 notice.
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