Protocols & Policy · Bank access
The Office of the Comptroller of the Currency's final debanking report, released Oct. 14, says JPMorgan Chase, Bank of America and seven other large national banks restricted lawful sectors from 2020 to September 2025. Digital-asset firms were one of six sectors named. The report imposes no new rule.
The Office of the Comptroller of the Currency said on Oct. 14 that all nine of the largest national banks it supervises had policies that limited service to customers over their views or their lawful business, and digital-asset companies were among the businesses named. The banks are JPMorgan Chase Bank, Bank of America, Citibank, Wells Fargo Bank, U.S. Bank, Capital One, PNC Bank, TD Bank and BMO Bank (source 1).
"Debanking" here means closing or refusing an account, or adding conditions to one, for reasons other than measurable financial risk. The OCC's report, "Guaranteeing Fair Banking for All Americans," is the final version of a review it opened in September 2025 under Executive Order 14331 and first summarized in preliminary findings in December 2025 (sources 1, 2).
Why it matters now: crypto firms have argued for years that banks cut them off. This is the national bank regulator saying, in a final report, that many of the biggest banks did restrict the sector. It does not change any law, and it does not order any bank to reopen an account.
The review covered "the period between 2020 and September 2025," the report says. "In total, the OCC reviewed nearly 100,000 complaints, hundreds of individual bank decisions, and about 420,000 pages of bank documents" (source 2, p. 1). The press release adds that the pages came in "approximately 50,000 documents" from the nine banks (source 1).
The OCC grouped what it found into two kinds of policy. One was reputation-risk practices, which "restricted entering or maintaining customer relationships to manage 'reputation risk.'" The other was industry-specific practices that "restricted certain industry sectors' access to financial services for reasons unrelated to financial or operational concerns." Those ranged "from categorical prohibitions to escalated reviews and approvals" (source 2, p. 12).
The release's summary: "between 2020 and September 2025, all nine banks had such policies" (source 1).
Digital assets are one entry on a list. The release names six restricted sectors: oil and gas exploration; coal mining or coal-powered plants; firearms or ammunition; detention facilities; tobacco or e-cigarettes; "and digital asset activities" (source 1).
The report's own entry on crypto is a single sentence: "Many institutions also placed restrictions on banking digital asset activities, including on issuers, exchanges, or administrators, often attributed to financial crime considerations" (source 2, p. 27).
That last clause matters. The banks' stated reason for the crypto limits was financial crime, which is a compliance concern, not only a public-image one. The OCC's broader finding is that, across the restricted sectors, "the bases for these restrictions often extended beyond core financial risks and instead focused on the impacts to the banks' reputation" (source 2, p. 28). The report does not break out how often that was true for digital-asset customers specifically.
The report says the banks have revised their policies. "Various banks noted how these reviews resulted in the elimination or narrowing of prohibited business classifications," including "the removal or relaxation of restrictions affecting certain industries such as firearms, tobacco, and digital assets" (source 2, p. 42).
The OCC does not take that at face value. "It is difficult to assess at this stage whether these recent steps have a practical effect on decision making," it writes, adding that "changes in the wording of policies do not always correspond with changes in practice" (source 2, p. 42).
It also flags a quieter route to the same outcome. Some banks said particular business lines did not serve some customers because they "lacked the expertise, controls, or operational capacity." The report adds: "Examples included business line limitations involving certain digital-asset and money-services businesses." The OCC says these "may raise concerns" where they leave smaller firms "categorically being denied access to critical financial services" or where "'operational' limitations entrench industry restrictions" (source 2, p. 42).
Le Coin's view: the second-order effect runs through bank supervision, not through crypto law. The report itself bans nothing. The tools that could change bank behavior toward crypto customers are the ones the OCC lists in its own section on next steps (source 2, pp. 43-44):
For a crypto exchange or stablecoin issuer looking for a bank, the practical question is whether a refusal now has to rest on a documented, risk-based reason. The report's standard is that decisions "should reflect a bank's assessment of a customer or prospective customer, after applying measurable, impartial, risk-based standards that the institution adopts in advance" (source 2, p. 1).
The objection is that crypto's banking problem was never mainly about image. The report records that the banks themselves cited financial crime for the digital-asset limits (p. 27). Anti-money-laundering obligations still apply in full, and nothing in this report relaxes them. A bank that declines a crypto firm on documented AML grounds is not what the report criticizes.
The report is also a supervisor's findings about its own banks, not a court ruling, and it names no individual crypto customer that was refused.
The OCC says it "is considering further rulemaking options to prevent banks from discriminating against customers or prospective customers on the basis of their political or religious beliefs and to address the problematic role of reputation risk" (source 2, p. 44). Comptroller of the Currency Jonathan V. Gould said in the release that the OCC "will be assessing further changes to the regulatory and supervisory framework applicable to the largest banks" (source 1). No proposed rule or date was announced on Oct. 14.
Holding the Corner.
Not financial advice.