The Office of the Comptroller of the Currency (OCC) published its final OCC debanking report on 14 October 2026. It covers the nine largest national banks the OCC supervises: JPMorgan Chase Bank, Bank of America, Citibank, Wells Fargo Bank, U.S. Bank, Capital One, PNC Bank, TD Bank and BMO Bank. All nine, the regulator found, had policies between 2020 and September 2025 that could deny or limit service because of a customer’s political or religious beliefs or lawful line of business. Crypto is one of six restricted sectors. The report says many of these banks limited service to digital asset issuers, exchanges and administrators, often citing financial-crime concerns.
That is the full crypto finding. The 47-page report describes no crypto case, ties no named bank to digital assets and announces no fine or referral against any of the nine.
Nine banks, 420,000 pages, nearly 100,000 complaints
The review was ordered under Executive Order 14331, “Guaranteeing Fair Banking for All Americans”, which President Donald Trump signed on 7 August 2025. The OCC sent its first information requests to the banks on 5 September 2025, according to the report (page 10). Examiners read nearly 100,000 complaints filed between January 2020 and December 2025. They also went through about 50,000 documents from the banks, roughly 420,000 pages, and tested hundreds of individual decisions to open, expand or end customer relationships.
The nine were picked by size. Together they hold a majority of the assets of the commercial banks and savings associations the OCC supervises, which came to $16.7 trillion on 30 September 2025. The figures below are taken from the chart on page 10 of the report.
| Bank | Total assets, 30 Sept 2025 (OCC report, p. 10) |
|---|---|
| JPMorgan Chase Bank | $3.8 trillion |
| Bank of America | $2.7 trillion |
| Citibank | $1.8 trillion |
| Wells Fargo Bank | $1.8 trillion |
| U.S. Bank | $683 billion |
| Capital One | $652 billion |
| PNC Bank | $564 billion |
| TD Bank | $476 billion |
| BMO Bank | $249 billion |
| All other OCC-regulated commercial institutions | $4 trillion |
The main finding is about how decisions were made. Broad “reputation risk” policies, the OCC says, lacked clear standards and objective, risk-based criteria, and some banks still weigh the same idea under the label of “franchise” or “brand” risk. No bank, according to the report, has fully and publicly acknowledged its past debanking decisions.
Six lawful sectors appear on the list of businesses the banks restricted: oil and blockchain come Ethereum. Il gas misura il lavoro di calcolo richiesto da una transazione e la commissione è pari al gas usato moltiplicato per il prezzo unitario del gas.">gas exploration, coal mining and coal-fired power, firearms and ammunition, detention facilities, tobacco and e-cigarettes, and digital asset activities.
Most of the case studies have nothing to do with crypto. In February 2021 a payment processor owned by one bank closed the account of a merchant selling MAGA merchandise. Two years later a bank declined to serve a public education group because of its partisan leanings. A firearms company was refused help with an IPO because its sales policy did not match the bank’s own firearms standards. At TD, a reputation-risk team recommended against a small-business loan of less than $50,000 to a maker of rifle components; in later years the same bank approved a multimillion-dollar letter of credit for a large multinational gun maker. Religious and political nonprofits, coal companies, a home healthcare provider and a high-net-worth client also appear.
The regulator concedes a limit. It was “unable to quantify on a comprehensive basis the full extent of debanking or alleged debanking actions” across the nine banks, or what they cost customers.
What the OCC debanking report says about crypto
The crypto passage sits on page 27 under the heading “Digital Asset Activities”. It is one sentence: “Many institutions also placed restrictions on banking digital asset activities, including on issuers, exchanges, or administrators, often attributed to financial crime considerations.”
Issuers would include the companies behind stablecoins and other tokens. Exchanges are trading platforms. The report does not define “administrators”.
The stated reason is different from the rest of the report. On coal, Gould said in his prepared remarks that banks “cited concerns about negative headlines, public protests” rather than financial risk. For crypto, the report points to financial crime, which in banking means anti-money-laundering and Bank Secrecy Act (BSA) compliance. The OCC does not say crypto firms were refused service for their politics.
Digital assets come up twice more, both on page 42. Various banks told the OCC they had removed or relaxed restrictions on “certain industries such as firearms, tobacco, and digital assets”. The regulator says it is “difficult to assess at this stage” whether that changes how decisions are made. Footnote 22 adds that some banks kept restrictions where activity implicated money laundering or other financial crime, and that some business lines still do not offer certain products to some customer types for lack of expertise or controls. Its examples include “certain digital-asset and money-services businesses”. The OCC says such limits “may raise concerns” when small and medium-sized firms are denied as a category.
Four things are absent from the crypto passages:
- an example of a crypto company losing an account, a loan or a payment service;
- a count of affected crypto customers or a dollar figure;
- the name of any bank in connection with digital assets;
- a fine, consent order or Justice Department referral, for crypto or for any other sector.
Cointelegraph, which put crypto in its headline, also wrote that the report “did not include specific examples” tied to digital assets. Our reading of the PDF agrees.
The sector list has changed since the preliminary findings of 10 December 2025, which covered 2020 to 2023 and named adult entertainment as well as digital assets. Adult entertainment is not on the October list. Digital assets are.
The CFPB opens an investigation as JPMorgan pushes back
Comptroller Jonathan V. Gould said the report “provides irrefutable evidence that the nation’s largest banks have denied, debanked and discriminated against customers and lawful businesses”. He added: “Notwithstanding certain efforts by the largest banks to rein in these practices, I am not confident that they will be enough.”
Gould presented the findings at a press conference in Lexington, Kentucky, with Representative Andy Barr, where coal and firearms industry representatives spoke (OCC release 2026-91). His remarks do not mention crypto. One passage set out the regulator’s position: “We are not forcing these banks to serve every customer. Instead, banks should evaluate every customer on objective, risk-based criteria.”
The Consumer Financial Protection Bureau acted the same day. Acting Director Mark Paoletta announced an initiative and said: “The CFPB will fully investigate whether the institutions featured in OCC’s report and others have complied with federal consumer financial laws.” His statement attacks the previous administration in partisan terms. It says nothing about crypto and sets no timetable.
JPMorgan, quoted by Banking Dive, said the findings reflected “a limited number of historical interactions” and that it has “improved the way we do business”. The Bank Policy Institute, which represents large banks, told American Banker: “We support efforts to establish clear and consistent standards that promote access while maintaining sound risk management”.
By 17:50 UTC we had found no public statement on the report from Coinbase, the Blockchain Association, Custodia Bank or Coin Center, and no written reaction from a member of Congress.
From “Choke Point 2.0” to an official record
“Operation Choke Point 2.0” is the crypto industry’s name for what firms say happened from 2023: banks dropping crypto clients after quiet pressure from supervisors. It borrows the name of an Obama-era Justice Department programme aimed at payment processors. The Republican majority staff of the House Financial Services Committee put it in the title of a late-2025 report, “Operation Chokepoint 2.0: Biden’s Debanking of Digital Assets”, which Gould said on 1 December 2025 “confirms what many have long suspected”. The OCC’s new report never uses the phrase.
The episode runs from early 2023 to today’s report.
| Date | Event |
|---|---|
| 3 Jan 2023 | Fed, FDIC and OCC issue a joint statement on crypto-asset risks to banks (a second, on liquidity, follows on 23 Feb) |
| 8 Mar 2023 | Silvergate Capital announces the wind-down and voluntary liquidation of Silvergate Bank |
| 12 Mar 2023 | New York regulators close Signature Bank; the FDIC becomes receiver |
| 5 Feb 2025 | FDIC releases 175 documents on crypto supervision, after publishing 25 “pause” letters sent to 24 institutions |
| 7 Mar 2025 | OCC Interpretive Letter 1183: crypto custody, some stablecoin activities and node participation no longer need prior supervisory non-objection |
| 20 Mar 2025 | OCC stops examining banks for reputation risk |
| 7 May 2025 | OCC Interpretive Letter 1184: banks may buy and sell custodied crypto at a customer’s direction |
| 7 Aug 2025 | Executive Order 14331 signed |
| 10 Dec 2025 | OCC preliminary findings on the nine banks (2020 to 2023) |
| 7 Apr 2026 | OCC and FDIC final rule barring supervisory action based on reputation risk (in force 9 June) |
| 14 Oct 2026 | OCC final debanking report; CFPB announces its investigation |
Travis Hill, then acting chairman of the FDIC, said in February 2025 that crypto requests from banks had been “almost universally met with resistance”. The pause letters told banks to hold off on new crypto activity. Silvergate and Signature, two banks with large crypto client bases, went down within four days of each other in March 2023.
The executive order itself does not mention crypto or digital assets. It calls the original Operation Choke Point a “well-documented and systemic means” of pushing banks away from lawful industries that regulators disfavoured. It gave regulators 120 days to review their banks and allowed remedies such as fines and consent decrees. The final report arrived more than 14 months after the signature.
What has changed for crypto firms since 2025
Since early 2025, regulators have opened other doors to the banking system for crypto firms, mostly outside the debanking review.
Trust charters
On 12 December 2025 the OCC conditionally approved five national trust banks: two new banks, First National Digital Currency Bank (Circle) and Ripple National Trust Bank, plus conversions of state trust companies run by BitGo, Fidelity Digital Assets and Paxos. Circle received final approval on 10 July 2026. We found no OCC confirmation of final approval for the other four, so they remain conditionally approved.
Coinbase received conditional approval for a national trust company charter on 2 April 2026, aimed at its custody business; the company says it will not take retail deposits. For retail users, nothing changes at the account level. Our Coinbase review covers the exchange itself, and the custody angle links to the SEC’s crypto custody proposal of 1 October.
A Fed master account and a proposed payment account
Kraken Financial, a Wyoming special purpose depository institution, announced on 4 March 2026 that the Kansas City Fed had granted it a limited-purpose master account with a one-year initial term. Our Kraken review covers the exchange side. On 20 May 2026 the Fed proposed a narrower “payment account” with no discount window, no intraday credit, no interest and limits on closing balances. It is not final.
A legal challenge from community banks
Community banks object to the charters. On 2 October 2026 the Independent Community Bankers of America sued the OCC in federal court in Washington (case 1:26-cv-03441), challenging a March 2026 chartering rule, a 2021 interpretive letter and Protego’s conditional approval. The complaint counts 21 trust charters approved or conditionally approved under the Trump administration, at least 13 of them for crypto companies.
On supervision, the OCC-FDIC rule against using reputation risk took effect on 9 June 2026, according to the Federal Register. A week earlier, on 2 June, the OCC, Fed and FDIC deleted further references to reputation risk from shared guidance.
What comes next: possible rules and a CFPB probe, no penalties
The OCC says it “is considering further rulemaking options” on political and religious discrimination and on how banks use reputation risk, including reliance on third-party opinions. There is no draft and no date. The review is “nearing completion”, in the report’s words, so it is not formally closed.
For crypto firms, the passage to watch is on page 8. Because the report ties crypto restrictions to financial crime, its plans for the Bank Secrecy Act bear more on them than the reputation-risk rule does. The OCC lists possible guidance on applying BSA rules by risk, reforms to BSA supervision and changes “to prevent pretextual reliance on the BSA for account terminations” unrelated to real money-laundering concerns. It may also issue guidance or rules on notices to customers whose accounts are closed.
The CFPB investigation covers the nine banks “and others”, with no timeline. Customers who think they were debanked can file a complaint at HelpWithMyBank.gov, which now has instructions for reporting debanking.
The Federal Reserve proposed its own rule removing reputation risk on 23 February 2026, with comments due in late April. Only the proposal appears in the Federal Register as of 14 October.
In Congress, the two Barr bills Gould praised have not moved since 2025. The Fair Access to Banking Act, H.R. 987, has sat in the House Financial Services Committee since 5 February 2025; its Senate twin, S. 401 from Senator Kevin Cramer, is with the Banking Committee. The FIRM Act, which would bar federal banking agencies from considering reputational risk, was placed on the Senate calendar on 18 March 2025 (S. 875) and on the House Union Calendar on 20 June 2025 (H.R. 2702). Neither has had a floor vote, and bills not passed before the 119th Congress ends on 3 January 2027 lapse. For federal crypto law more broadly, see where US crypto rules stand after the CLARITY Act.
For readers in Europe
Nothing in the OCC report applies outside the United States, and the EU has run no comparable review of its banks. National safety nets exist for people refused an account. In France, the droit au compte lets a person turned down by a bank ask the Banque de France to designate one that must open an account with free basic services. In Italy, the conto di base introduced by Legislative Decree 37/2017, which transposed the EU payment accounts directive, gives consumers legally resident in the EU the right to a basic account. It covers individuals, not companies, so it does not help a crypto firm that loses its business account.