The Office of the Comptroller of the Currency released findings on October 14 identifying historical restrictions on digital asset businesses across the nine largest national banks under its supervision. The review covered policies between 2020 and September 2025 at JPMorgan Chase Bank, Bank of America, Citibank, Wells Fargo Bank, US Bank, Capital One, PNC Bank, TD Bank, and BMO Bank.
The OCC's investigation examined nearly 100,000 complaints and reviewed approximately 50,000 documents totaling about 420,000 pages. The agency found that many institutions restricted banking services for digital-asset issuers, exchanges, and administrators, often citing financial crime considerations. Restrictions ranged from categorical prohibitions to additional reviews and approvals.
Comptroller Jonathan Gould stated that banks should evaluate customers using objective, risk-based criteria rather than broad sectoral exclusions. The OCC's approach preserves banks' ability to decline individual customers on legitimate grounds while limiting decisions based on business unpopularity.
New Supervisory Framework
The OCC and Federal Deposit Insurance Corporation issued a final reputation-risk rule on April 7, effective June 9. The rule prohibits supervisory pressure on banks over customer relationships based on public-perception concerns separate from financial or operational conditions. The rule explicitly prohibits supervisors from using anti-money laundering concerns as a pretext for reputation-risk supervision, while preserving Bank Secrecy Act enforcement authority and exempting OFAC-sanctioned entities.
In a separate enforcement action, the OCC assessed a $750 million civil money penalty against Bank of America on October 13 for transaction-monitoring, reporting, expertise, and training deficiencies.
Tools for Ongoing Compliance
The OCC has clarified that it will consider banks' debanking records and prevention policies case by case when applying licensing factors. Debanking decisions may also be examined under Community Reinvestment Act ratings, tailored to each bank's size, complexity, and risk profile. The agency updated its complaint reporting process in September 2025 and uses complaints to refine examinations.
The Office of Foreign Assets Control maintains that US persons have the same obligations for digital currency transactions as for traditional currency transactions.
Institutional Banking Services Emerge
On June 29, 2026, BNY announced stablecoin services for institutional clients, including custody of USDC and the ability to mint or redeem USDC through arrangements with Circle. The service extends to BNY's institutional clients, while access for smaller crypto businesses remains unresolved.
The OCC indicated it is considering further regulatory and supervisory changes. Progress will be measured by broader banking access that translates into actual customer availability of banking functions, with financial, operational, anti-money laundering, and sanctions requirements assessed on individual merits.
