The OCC found historical digital-asset restrictions at many of the nine largest national banks. New rules target reputation-based exclusions, while smaller crypto firms still face individual risk reviews and uncertain access to core services.
BNY's stablecoin service gives institutional clients a way to hold USDC in custody and instruct Circle to mint or redeem it against dollars. That offering does not guarantee comparable services for smaller crypto businesses.
Nine of the largest national banks face renewed scrutiny over past restrictions on digital-asset businesses. The OCC's findings do not guarantee crypto firms access to banking. Banks may still reject individual customers on objective risk grounds. The agency's challenge is to distinguish those assessments from exclusions based on a business's unpopularity.
What the review found
The OCC announced its review in September 2025 and presented preliminary findings that December. On October 14, 2026, it published a report on practices at nine banks. The institutions included JPMorgan Chase Bank and Bank of America. Citibank and Wells Fargo Bank were also covered. U.S. Bank and Capital One were included, along with PNC Bank. TD Bank and BMO Bank completed the group. The review covered policies and practices from 2020 through September 2025.
The OCC said all nine banks had policies that could restrict service based on political views or religious views. The policies could also affect customers because of lawful business activity.
The report identified restrictions affecting oil and gas and coal mining. It also covered weapons manufacturing. Detention facilities and tobacco were among the other industries discussed. Digital assets were another affected sector. The OCC said many institutions restricted banking for digital-asset issuers, often citing financial-crime concerns. Exchanges and administrators were also affected.
The broader inquiry included nearly 100,000 complaints and about 50,000 documents totaling roughly 420,000 pages. Those figures cover the OCC's work across customer sectors, not crypto complaints alone. The agency's large-bank report describes the review's scale and scope.
The findings describe restrictions across the nine banks, but say digital-asset restrictions occurred at many institutions. They do not establish that every bank adopted a categorical ban. Nor do they explain the grounds for each individual refusal. Those questions require case-level review.
Crypto firms can also face network-level operational failures. The Zano rollback illustrates that risk. It is separate from whether a bank may exclude a lawful business category outright.
Where rules draw the line
The OCC and Federal Deposit Insurance Corporation issued a final reputation-risk rule on April 7. It took effect June 9. The rule limits how the agencies supervise banks and pressure them over customer relationships. It defines reputation risk as public-perception concerns separate from a bank's financial or operational condition, while preserving Bank Secrecy Act enforcement authority. Its account-relationship provision exempts persons, entities, or jurisdictions subject to OFAC sanctions.
The rule's explanation bars supervisors from using anti-money-laundering concerns as a pretext for reputation-risk supervision. Banks still have to manage financial-crime exposure and sanctions risk. They remain responsible for operational and compliance risks, too. The OCC must assess whether a restriction reflects a customer's risks and the bank's ability to manage them, rather than disapproval of the customer's lawful business.
Comptroller Jonathan Gould has said banks should use objective, risk-based criteria while retaining the ability to decline individual customers on those grounds. The August 2025 fair-banking executive order, titled "Guaranteeing Fair Access to Banking for All Americans," takes a similar approach. It creates no privately enforceable right or benefit and leaves existing statutory protections intact.
Financial-crime controls remain in force. On Oct. 13, the OCC assessed a $750 million civil money penalty against Bank of America, citing deficiencies in transaction monitoring and reporting. The agency also cited gaps in expertise and training. Separately, the Office of Foreign Assets Control says digital-currency transactions carry the same obligations for people under U.S. jurisdiction as traditional fiat transactions.
Access tools and limits
The OCC can examine banks' customer-access decisions through existing licensing and supervisory processes. A September 2025 bulletin said the agency considers debanking records and prevention policies case by case when applying relevant licensing factors. It may also consider debanking in Community Reinvestment Act ratings. How it does so depends on a bank's size and complexity, as well as its overall risk profile. CRA consideration is discretionary, and licensing decisions remain case-specific.
The agency updated its online complaint reporting in September 2025 and says complaints and other data inform examinations. For a crypto business, a documented refusal may become relevant to supervisory review. Those tools do not promise an account or require a bank to accept every applicant.
The Bank Policy Institute has backed fair access and consistent standards while supporting sound risk management. JPMorgan said its policies prohibit political or religious discrimination. The bank also said it corrected a WePay process that fell short of its standards.
BNY's June 29, 2026 announcement offers institutional clients custody of USDC. Those clients can also instruct Circle to mint USDC from dollars or redeem it for dollars. The service links digital-asset custody with stablecoin issuance and redemption, but eligibility for smaller crypto businesses remains unresolved. Its wider competitive effects are unresolved as well. The OCC says it is considering further regulatory and supervisory changes.
A crypto business may need a deposit account, custody, or payment and redemption services. Each service has its own provider eligibility rules. Stablecoin minting and redemption also depend on the bank and issuer relationship described in BNY's announcement. The announcement does not establish that every crypto firm can use the service. For smaller businesses, access still turns on a bank's assessment of the customer and its ability to manage the associated risks.
