Banking for Bitcoin businesses: who serves crypto firms, and on what terms

Researched 2026-10-09. This is research, not legal or financial advice, and not a recommendation of any bank. It records what public sources said on the dates given; terms change, and any bank decides each account case by case. Saved government and court documents are in sources/banking/ (see sources/banking/INDEX.md). Company pages and news are summarized here with links, not saved. Anything unverified is marked "(unverified)", and contested claims are labelled as contested.

Summary

• 2021–2024: hard. Between November 2021 and August 2023 all three federal bank regulators required banks to give notice of crypto activities, or get permission first. The OCC's term was "supervisory non-objection"; the FDIC sent "pause" letters. Their joint statements called holding crypto on public blockchains "highly likely to be inconsistent with safe and sound banking practices". Most banks that asked permission withdrew their requests. Then the three banks best known for serving crypto firms failed or shut down in March 2023: Silvergate, Silicon Valley Bank and Signature.
• "Operation Choke Point 2.0" is contested. A House majority staff report (2025-12-01) and the FDIC's own acting chairman (2025-02-05) describe a coordinated effort to cut crypto off from banks. Fed officials, Senate Democrats and New York's bank regulator disputed parts of that account. What the documents do show is set out in section 1.3.
• 2025–2026: the rules reversed.
• The guidance was withdrawn between March and August 2025.
• "Reputation risk" was dropped from bank exams, then banned by an OCC/FDIC rule effective 2026-06-09.
• Executive Order 14331 (2025-08-07) targets "politicized or unlawful debanking".
• The OCC has conditionally approved more than a dozen national trust banks for crypto and stablecoin firms. One of them is Coinbase's (2026-04-02).
• The Fed lists Kraken Financial, a Wyoming SPDI, as the first crypto-native firm approved for a master account. Its database gives 2026-01-28; news reports say March 2026, and that the account was not yet usable as of July 2026.
• Custodia Bank lost its master-account suit in the Tenth Circuit (2025-10-31; rehearing en banc denied 2026-03-13). As of 2026-08-18 it was asking the Supreme Court to review the case.
• Who banks crypto firms now (per public sources):
• Mid-size banks that provide operating accounts, on- and off-ramps between dollars and crypto, and 24/7 settlement: Cross River, Customers Bank (cubiX, formerly CBIT), Western Alliance and Lead Bank.
• Newer crypto-specialist charters: Anchorage Digital Bank, Kraken Financial and Erebor Bank.
• Big banks offering custody and consumer access: U.S. Bank, PNC, JPMorgan Chase, Citi and SoFi.
• For a walk-in shop or ATM operator, the gate is now mainly AML/BSA rather than "reputation".
• A walk-in Bitcoin seller is generally a money services business (MSB).
• Some fintech account providers exclude MSBs outright; Mercury says so on its site.
• Banks that do take MSBs apply the 2005 interagency due-diligence steps: FinCEN registration, state licenses and a risk assessment.
• The OCC's 2026 denial of Wise's trust-bank charter shows how heavily a weak AML record now counts.

1. Why crypto businesses found banking hard (2021–2024)

1.1 The supervisory letters and joint statements

Sources: the documents themselves, saved in sources/banking/ (the Fed copies carry the agency's "withdrawn" stamp); Fed press releases of 2022-08-15 and 2022-08-16, 2023-01-03, 2023-01-27, 2023-02-23 and 2023-08-08; FDIC OIG EVAL-24-01; FDIC release of 2025-02-05.

What happened to the permission requests. The OCC published every formal IL 1179 request and its answer ("Summary of Interpretive Letter 1179 Requests", cited in OCC NR 2025-114, 2025-12-01). As listed there:

• Withdrawn, never approved:
• three requests to hold stablecoin reserve deposits (made 2022-01-06, 2022-01-20 and 2022-12-30);
• a request to offer crypto custody to existing custody clients (2022-03-30, withdrawn 2023-03-27);
• a crypto custody beta test (2022-06-16, withdrawn 2023-06-08).
• Given non-objection: banks' own internal-blockchain projects, such as tokenized deposits and intraday repo on a private ledger (2023–2024).

Our reading, not the OCC's: the pattern is that permissioned, bank-run ledgers got through and public-chain crypto custody and stablecoin work did not.

Accounting. The SEC staff's 2022 accounting guidance (Topic 5.FF, added by SAB 121) made custodians record customers' crypto as a liability on their own balance sheets, which, by industry accounts, made custody impractical for banks. SAB 122 rescinded that guidance on 2025-01-23 (SEC, https://www.sec.gov/rules-regulations/staff-guidance/staff-accounting-bulletins/staff-accounting-bulletin-122). That banks found custody impractical under the 2022 guidance is (unverified) here; the 2025 rescission is confirmed.

1.2 The March 2023 failures

Silvergate Bank (La Jolla, CA). Silvergate ran the Silvergate Exchange Network, the main 24/7 dollar-transfer system between crypto exchanges and traders before 2023 (unverified from primary sources here).

• 2023-03-08: Silvergate announced a voluntary wind-down and liquidation.
• 2023-05-23: Fed and California DFPI consent order to make sure the liquidation "protects the bank's depositors" (announced 2023-06-01).
• 2024-06-04: Fed civil money penalty of $43 million for "deficiencies in Silvergate's monitoring of transactions in compliance with anti-money laundering law". Penalties from the Fed and the state totalled $63 million; announced 2024-07-01. The SEC brought a separate action.
• 2024-07-26: the Fed ended its order, saying Silvergate "has paid back all deposits to its customers, and no longer functions as a bank".

Silicon Valley Bank (Santa Clara, CA). SVB was a technology-industry bank, not a crypto bank, but it held a large share of a stablecoin's reserves.

• 2023-03-10: SVB entered resolution "after experiencing over $40 billion in withdrawals from depositors in a single day".
• That evening Circle said it could not withdraw $3.3 billion of USDC reserves from SVB, about 8% of the total.
• USDC fell to 86 cents at its low.
• Source: Fed FEDS Note, 2025-12-17. The Fed's own SVB review (2023-04-28) blames SVB's management and Fed supervision; it does not treat crypto as a cause.

Signature Bank (New York). Signature ran Signet, "a blockchain-based digital payment platform" for its business clients, which it developed with Tassat in 2018 (FDIC report).

• Its digital-asset deposits grew from $1.7 billion at end-2019 to $28.7 billion at end-2021, which was 27% of all its deposits. They were $17.8 billion at end-2022.
• 2023-03-12: New York's Department of Financial Services (NYDFS) closed the bank.
• 2023-03-19: Flagstar Bank bought most of it from the FDIC. The bid excluded about $4 billion of deposits "related to the former Signature Bank's digital-assets banking business", which the FDIC paid out directly to those customers.
• The FDIC's own review blamed "poor management" and over-reliance on uninsured deposits. It also said Signature "failed to understand the risk of its association with the crypto industry".
• Sources: FDIC, FDIC's Supervision of Signature Bank, 2023-04-28 (Table 1); FDIC release, 2023-03-19.

Contested: was Signature closed to send an anti-crypto message? - Claim: Barney Frank, a Signature board member and former congressman, said on 2023-03-13 that "regulators wanted to send a very strong anti-crypto message" (as reported by Decrypt, https://decrypt.co/123346/signature-bank-shut-down-anti-crypto-barney-frank). - Response: NYDFS's internal review (2023-04-28) concluded that Signature's association with crypto was not a contributing factor. Digital-asset customers' withdrawals on 2023-03-10 were roughly proportional to their share of deposits. The "bigger issue" was a high concentration of uninsured deposits and being "perceived as a crypto bank". Source: House Financial Services Committee summary of the NYDFS report, 2023-05-02 (saved). The NYDFS original could not be downloaded; see the gaps list.

Effect. Three banks that served crypto firms were gone within five days. The specialist 24/7 settlement networks (Silvergate's SEN and Signature's Signet) went with them. In February 2025, Anchorage Digital's chief executive told the Senate Banking Committee three things. A partner bank gave Anchorage 30 days' notice in June 2023 to close its corporate account "because they were not comfortable with our crypto clients". After the banks holding its capital reserve and fiat sub-custody accounts closed, Anchorage "spoke to about 40 banks across the country and were rejected by all of them". The joint statement of 2023-01-03 was "the nail in the coffin". Source: S. Hrg. 119-364, hearing of 2025-02-05.

1.3 "Operation Choke Point 2.0": the claim and the dispute

The claim. - On 2025-02-05 the FDIC's Acting Chairman, Travis Hill, released 175 documents. He said banks' crypto requests "were almost universally met with resistance" and that "the vast majority of banks simply stopped trying". - The House Financial Services Committee majority staff report, Operation Choke Point 2.0: Biden's Debanking of Digital Assets (2025-12-01), says regulators "used vague rules, excessive discretion, informal guidance, and aggressive enforcement actions to pressure banks away from serving digital asset clients". It says the result was "at least 30 digital asset entities or individuals losing access to financial services". Sourcing note: the report's footnote for "at least 30" cites Marc Andreessen's 2024-11-26 appearance on the Joe Rogan podcast, not a documented list. - The OCC's preliminary findings (2025-12-10) say the nine largest national banks kept policies in 2020–2023 restricting or escalating service to certain lawful sectors, "digital assets" among them, "often attributed to financial crime considerations". The nine are JPMorgan Chase, Bank of America, Citibank, Wells Fargo, U.S. Bank, Capital One, PNC, TD and BMO.

Disputes and qualifications (contested). - Fed Vice Chair for Supervision Michael Barr said on 2025-02-20, about crypto clients: "We don't tell them that they have to do it, we don't tell them they shouldn't" (as reported by The Block, https://www.theblock.co/post/342512/feds-michael-barr-responds-crypto-debanking-concerns-central-bank). - The February 2023 joint statement itself said banks are "neither prohibited nor discouraged" from serving any class of customer. - At the 2025-02-05 Senate hearing, Ranking Member Elizabeth Warren treated debanking as a broad problem that is not specific to crypto. Her staff found 11,955 Consumer Financial Protection Bureau (CFPB) complaints in three years, half of them against four big banks (Bank of America, JPMorgan, Wells Fargo, Citibank). She blamed banks' own risk shortcuts. - NYDFS's finding on Signature is above. - The regulators' stated reasons in 2022–2023 were safety and soundness after the crypto failures of 2022 (the joint statements cite "significant volatility and vulnerabilities over the past year").

What is documented either way. The non-objection and notice requirements, the FDIC pause letters, the open-ended reviews the FDIC Inspector General criticized, the withdrawn OCC requests, and the large banks' written sector restrictions. Whether these add up to a coordinated political campaign remains disputed.

2. What changed (2025–2026)

2.1 Timeline

2.2 The August 2025 executive order: what it does and does not do

EO 14331 (signed 2025-08-07; 90 FR 38925) does the following:

• Defines "politicized or unlawful debanking": restricting a customer's access "on the basis of the customer's ... political or religious beliefs, or on the basis of the customer's ... lawful business activities that the financial service provider disagrees with or disfavors for political reasons".
• Orders regulators to remove "reputation risk" from guidance within 180 days and to consider rule changes.
• Orders a review within 120 days of banks' past or present debanking policies, with possible fines or consent decrees.
• Requires SBA-lender reinstatement steps.
• Asks Treasury for a strategy within 180 days.
• Sets the policy that banking decisions be "made on the basis of individualized, objective, and risk-based analyses".

The order text does not mention crypto or digital assets; it does not use either word. Crypto falls under "lawful business activities". Our reading, not legal advice: the order does not give anyone a right to an account. A bank may still refuse a customer on "individualized, objective, and risk-based" grounds, and AML risk is such a ground.

Follow-through so far: - The OCC's review of its nine largest banks (findings 2025-12-10). - The OCC/FDIC reputation-risk rule (effective 2026-06-09) and the Fed's proposal (2026-02-23). - OCC bulletins making debanking a factor in licensing and Community Reinvestment Act ratings (2025-09-08). - In the House, Rep. Andy Barr announced a bill to write the order into law (August 2025, per his office: https://barr.house.gov/2025/8/barr-announces-introduction-of-bill-to-codify-president-trump-s-debanking-executive-order). Its status was not checked here.

2.3 OCC charters for crypto, stablecoin and fintech firms (2025–2026)

All are preliminary conditional approvals unless marked otherwise. National trust banks "will not take deposits and will not be insured by the Federal Deposit Insurance Corporation" (as stated in the BitGo and Paxos letters). They offer custody and related services, not checking accounts.

Other relevant OCC actions: - Anchorage Digital Bank, N.A. was the first crypto national trust bank (chartered January 2021). The OCC ended its 2022 cease-and-desist order on 2025-08-21 and its 2021 Operating Agreement on 2026-02-09. - Pushback (contested). The Independent Community Bankers of America (ICBA) reportedly sued the OCC in about October 2026, arguing it cannot charter "non-fiduciary" crypto trust banks. Source: news headline only, https://cryptocapitalnews.com/2026/10/04/icba-lawsuit-tests-whether-the-occ-can-charter-non-fiduciary-crypto-trusts-at-all (unverified; court filing not found).

2.4 Federal Reserve master accounts, Custodia, and the "payment account"

A master account is a bank's own account at a Federal Reserve Bank. Without one, a bank must route payments through a correspondent bank.

Custodia Bank v. Federal Reserve. - 2023-01-27: the Fed denied Custodia, a Wyoming SPDI, membership in the Federal Reserve System. Its order cited "novel and untested crypto activities" and an insufficient risk-management framework, including for money laundering. The Kansas City Fed denied Custodia's master-account request the same day (Fed database: "Rejected, 1/27/2023"). - Custodia sued. The district court ruled for the Fed in 2024 (Custodia Bank v. Fed. Rsrv. Bd. of Governors, 728 F. Supp. 3d 1227 (D. Wyo. 2024), as cited by the Tenth Circuit). - 2025-10-31: the Tenth Circuit affirmed. Judge Ebel wrote the opinion; Judge Tymkovich dissented. - The court held that 12 U.S.C. § 342 gives Reserve Banks discretion to reject master accounts even for eligible institutions. - It held that § 248a ("shall be available to nonmember depository institutions") is a pricing rule and does not require access. - It said the 2022 "Toomey Amendment" database statute "clearly contemplates that Reserve Banks may reject applications". - 2026-03-13: rehearing en banc denied. Judges Hartz, Tymkovich and Eid voted to rehear. Judge Tymkovich's dissent warned that unreviewable discretion hands "the Reserve Banks a veto over states' chartering power". - As of 2026-08-18, Custodia had petitioned the Supreme Court, the Blockchain Association had filed in support, and the Court had not acted (PYMNTS, https://www.pymnts.com/cryptocurrency/2026/blockchain-group-asks-supreme-court-review-federal-reserve-denial-crypto-bank-bid-master-account). Docket number not found. - The Fed database also lists a second Custodia request, filed 2026-02-06 and assigned to the Dallas Reserve Bank district, withdrawn 2026-05-21. That was the day after the Fed asked Reserve Banks to pause Tier 3 decisions. The reason for the withdrawal was not found.

Kraken Financial (Wyoming SPDI). - The Fed's database (page updated 2026-09-18) lists Kraken Financial's request, filed 2020-10-06, as approved 2026-01-28, Tier 3. Kraken also appears in the list of existing account holders, effective 2026-01-28. It is the first crypto-native institution in the database with an account. - Contested or unclear: PYMNTS (2026-07-22) reported the approval as March 2026. It also reported a "limited-purpose" account for one year, approved but not yet operational, with services to start with institutional clients (https://www.pymnts.com/cryptocurrency/2026/kraken-cracked-the-feds-vault-it-still-cant-spend). No Fed press release on Kraken was found.

Other pending crypto-related requests in the Fed database (as of 2026-09-18), with filing dates:

Earlier outcomes: - Paxos withdrew its request on 2024-01-26. - TNB USA, a "narrow bank", was rejected on 2023-12-13. - Wise National Trust withdrew on 2026-07-24.

The "payment account." - 2025-12-19: the Fed requested public input on the idea. - 2026-05-20: the Fed proposed it formally. A payment account would have no interest, no intraday credit and no discount window, overdraft controls, and closing-balance limits based on expected payment activity. It "would not expand or otherwise change legal eligibility". - The same release asked Reserve Banks "to temporarily pause decisions on access requests from institutions that fall within Tier 3" until the policy is finished. That covers most crypto applicants listed above. - Sources: Fed releases; FR 2025-23712 and 2026-10375.

2.5 Wyoming special purpose depository institutions (SPDIs)

• Law. Wyoming created the SPDI charter in 2019 (House Bill 74; Wyo. Stat. § 13-12-101 et seq.), along with a digital asset law (Wyo. Stat. § 34-29-101 et seq.).
• What an SPDI is. SPDIs are "fully-reserved banks". They are "prohibited from making loans with customer deposits of fiat currency", and must back fiat deposits "100% or more by unencumbered liquid assets". They do custody, asset servicing and fiduciary work, and can hold business operating accounts. The Division of Banking says "the Wyoming Banking Board has approved four SPDI charters thus far" (program page, undated, retrieved 2026-10-09).
• Who they are. Wyoming institutions in the Fed database are Kraken Financial, Custodia Bank, Commercium Financial and N3XT; BankWyse withdrew its master-account request on 2024-05-31. That these four are the four approved charters is our inference (unverified).
• Status. SPDIs are not FDIC-insured, so all of them fall in Fed Tier 3. As of the database date, Kraken Financial was the only one with a master account.

3. Who serves crypto businesses, and on what terms (per public sources)

This is "who says they serve crypto businesses, and how", not a recommendation. Each row gives the source and its date. Public marketing pages describe offers, not approval odds; banks screen each customer.

3.1 Banks providing operating accounts, fiat on- and off-ramps, and 24/7 settlement

3.2 Big banks: custody and consumer access (not crypto-business operating accounts)

3.3 Fintech account providers

3.4 Signet's successors (24/7 dollar settlement between crypto firms)

Our reading, not a regulator's finding: Silvergate's SEN and Signature's Signet ended in 2023. Signature's digital-asset deposits were excluded from Flagstar's purchase (FDIC, 2023-03-19). The networks now publicly offering similar 24/7 dollar settlement for crypto firms are:

• Customers Bank's cubiX/CBIT (launched as CBIT before the 2024 written agreement; renamed cubiX by 2026);
• Cross River's CRNow;
• Western Alliance's settlement infrastructure;
• Anchorage's Atlas;
• Lead Bank's stablecoin rails.

This list comes from the sources in 3.1.

3.5 Banks that left, failed or were sold

3.6 Axos and others asked about

No public source found on 2026-10-09 describing an Axos Bank offering for crypto businesses. One 2023 news item (CryptoSlate) described Axos's client list as including crypto-industry figures, which says nothing about current terms. Treat Axos as not established for crypto-business banking.

4. Ease or difficulty for a walk-in Bitcoin shop, ATM operator or small exchange

The examples asked about include Bitcoin Central in New York and the walk-in shops near Chinatown in Las Vegas. The licensing side (NY BitLicense, Nevada) is covered in legislation/us-kyc-aml-selling-bitcoin.md and market/2026-10-09-walk-in-bitcoin-shops.md. This section is only about getting and keeping a bank account.

1. A walk-in seller is generally an MSB, and banks treat MSBs case by case. The 2005 interagency guidance, still on the FDIC's site, sets the bank's minimum due diligence for an MSB customer: - apply its Customer Identification Program; - "Confirm FinCEN registration, if required"; - "Confirm compliance with state or local licensing requirements"; - confirm agent status; - "Conduct a basic Bank Secrecy Act/Anti-Money Laundering risk assessment".

It says banks should not "treat all money services businesses as posing the same level of risk", and that a bank may insist on evidence of registration and licensing. Source: FIL-32-2005, 2005-04-26 (saved). 2. What changed since 2025 helps at the margin. - No federal regulator now requires a bank to get permission before serving crypto firms (OCC 2025-03-07, FDIC 2025-03-28, Fed 2025-04-24). - "Reputation risk" can no longer be used against a bank in OCC or FDIC supervision (rule effective 2026-06-09). - The OCC weighs debanking in licensing and Community Reinvestment Act ratings. 3. What did not change: AML is still the gate. - Silvergate was fined over AML transaction monitoring. - Customers Bank's written agreement targets AML controls for its digital-asset clients. - The OCC denied Wise's charter because of Wise US's record as an MSB. - The April 2026 AML proposal aims to focus banks on "higher-risk customers and activities". That is supposed to cut paperwork for low-risk accounts; whether it helps or hurts a cash-heavy crypto shop is not yet known (proposal stage). - Our inference: a cash-intensive walk-in crypto business will still be classed as higher risk by most banks. 4. Practical signals from public sources. - Mercury, a large fintech, excludes MSBs and exchanges. - The banks that publicly court crypto firms describe institutional customers: exchanges, stablecoin issuers, funds, OTC desks, fintechs. Western Alliance reports a $15 million average balance. - None of the sources reviewed advertises accounts for small, cash-handling crypto retailers. - The largest US bitcoin-ATM operator says in its FY2025 10-K that it uses armored couriers (Loomis, Brinks and Garda) for cash. Bitcoin Depot 10-K filed 2026-03-18, as extracted by a fetch tool; the banking risk-factor text could not be retrieved. 5. New-charter route. Large crypto firms are now getting their own OCC trust charters, and the OCC confirmed in IL 1192 that a national trust bank need not hold state money-transmitter licenses. That route is not open to a walk-in shop: these charters need substantial capital and governance, and trust banks do not offer checking accounts.

5. Gaps and things not verified

• The district court's 2024 summary-judgment opinion in Custodia (728 F. Supp. 3d 1227) is not saved, and its exact date was not verified. Custodia's Supreme Court docket number and status after 2026-08-18 were not found.
• The date of Kraken's master-account approval differs: the Fed database says 2026-01-28; PYMNTS says March 2026. Whether the account is live as of October 2026 is not confirmed.
• The original NYDFS Signature internal review could not be downloaded (HTTP 403); only the House committee's summary is saved.
• The FDIC's 790-page crypto correspondence (2025-02-05) is not saved because of its size (about 157 MB); only the release is.
• Bank-by-bank deposit figures for Customers Bancorp come from a tool reading SEC filings. The SEC blocks scripted downloads, so these were not read directly; check them in the 8-K before relying on them. Erebor's deposit figures are news-reported only.
• No primary source was found for Axos, Metropolitan Commercial Bank's exit, Cross River's 2026 consent-order status, the closing date of Silvergate's SEN, or Bank of America's 2026 adviser policy.
• The status of debanking bills in Congress, including Rep. Barr's bill to write EO 14331 into law and the Senate's Fair Access to Banking Act, was not checked.
• The ICBA suit against the OCC over crypto trust charters (about October 2026) is news-reported only.
• Which four institutions hold Wyoming SPDI charters is inferred, not confirmed by the Division of Banking.
• The Spark run on this topic (20261009-144200--how-hard-is-it-for-bitcoin-and-crypto-businesses-to-get-us-b) was still queued when this file was written. Update (completeness check, 2026-10-09): it finished at 23:13 UTC with all eight sub-answers CONFIDENT. Its rejected material is listed in RESEARCH-STATUS-2026-10-09.md § 6: one dropped fact, from the White House EO 14178 report; three refused pages (two LinkedIn, one Nasdaq); and two skipped pages, one of them the Federal Register EO 14178 text, which is saved here anyway. Two points in its summary are not adopted without checking. It names "Mercury, Chase" as banks serving crypto businesses. This note shows that Mercury serves crypto startups but says it does "not currently support Money Services Businesses or exchanges" (§ 3). For Chase it documents only the Coinbase partnership and consumer access, not accounts for crypto MSBs. It also cites a "Wall Street Journal survey" of about 120 crypto hedge funds, which is unverified (the WSJ was not read here). The rest has not been merged.