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Crypto companies have struggled to obtain basic banking services for several years. This problem has been given the friendly name “Operation Chokepoint 2.0,” harkening to the crackdown on payday lenders and other “high risk” category businesses from 2013 to 2015. This crackdown expanded to legitimate startups and resulted in blowback at the federal level. Last week, if any behind-the-scenes, coordinated “operation” has been keeping crypto companies down, the OCC signaled the end of that era with Interpretative Letter 1184.
The OCC’s letter clarified that national banks and federal savings associations can engage in crypto-asset activities on behalf of customers without seeking prior approval. Their attitude tracks the OCC’s 2020 guidance allowing banks to custody crypto, facilitate stablecoin payments, and run blockchain nodes. Although the May 2025 guidance only covers federal banks, state banks often look to federal guidance to determine their acceptable risk profile. It is a near certainty that state banks will see the OCC’s guidance and decide that banking crypto is, once again, fair game.
The letter guidance should operate as a key signal to banks that not only can they bank crypto customers, but they can also bank crypto companies. One hallmark of Chokepoint 2.0 has been crypto companies seeking money transmitter licenses (or “MTLs”) could not do so because they could not obtain trust accounts or “FBO” (for the benefit of) accounts at major banks. This means any startup wishing to compete against the likes of Coinbase or Kraken has effectively been stopped before they can start. Without a trust or FBO account (often called a “transactional” account) at a bank, a company cannot successfully apply for MTLs.
This chokehold has been part of the reason new centralized exchanges struggle to even launch within the U.S., and we do not have robust early-stage domestic competition for such exchanges. Beyond that, any company wishing to act as a stablecoin on- or off-ramp, or to perform cross-border remittance in cryptocurrency, or to even launch a stablecoin, will find incredible frustration when they reach the MTL stage of their lifecycle because of the years-long stubbornness within both federal and state banks refusing to provide transactional accounts to crypto MTLs.
After the OCC’s guidance, federal and state banks have the freedom to bank crypto companies seeking MTLs. While many banks will still consider these customers “high risk” due to anti-money laundering concerns, the OCC’s guidance gives these banks the runway to bring crypto MTLs back into the fold of U.S. financial services.
By the end of this year, expect to see more white-label agreements between crypto companies and banks, resulting in crypto-specific services within mainstream banking applications. Or, expect to see more sponsor agreements between banks and crypto companies, where traditional crypto apps are able to offer expanded banking services. By next year, as MTLs get granted to more and more crypto-focused companies, we will see a range of non-bank financial institutions offering stablecoin ramps, new stablecoin products, DeFi products, and other interesting crypto applications - regardless of what happens in Congress with respect to any crypto-specific bills. The OCC letter opens the door for a range of potential applications, and now that the doors have been nudged open, builders may be pushing through in droves.
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