OCC Debanking Report Names Digital Assets, Cites No Examples

The Office of the Comptroller of the Currency published its review of debanking at the nine largest national banks on Wednesday, and digital assets are on the list.

The OCC found that banks kept "public and nonpublic policies" restricting access to financial services for certain industries, from oil and gas exploration and coal mining to firearms, detention facilities, tobacco and digital asset activities. For several of those sectors, its own summary points to a specific incident. For digital assets, it points to none.

The regulator is also clear that it cannot size the problem. It said it was "unable to quantify on a comprehensive basis the full extent of debanking or alleged debanking actions" after reviewing nine major banks.

Nine Banks, $12.7 Trillion and Five Years of Policies

The nine institutions are JPMorgan Chase Bank, Bank of America, Citibank, Wells Fargo Bank, U.S. Bank, Capital One, PNC Bank, TD Bank and BMO Bank. Together they hold $12.7 trillion, or 76%, of the $16.7 trillion in total assets across OCC-regulated institutions, as of 30 September 2025.

The OCC looked at policies and practices from 2020 to September 2025 and found that all nine banks had policies that may have denied or limited access to financial services because of political or religious beliefs or lawful business activities.

The paperwork behind the finding was heavy: nearly 100,000 complaints to OCC-regulated institutions, and about 50,000 documents from the banks running to roughly 420,000 pages. The review was announced in September 2025, produced preliminary findings that December, and was conducted under Executive Order 14331, "Guaranteeing Fair Access to Banking for All Americans."

Digital Assets Get a Line, Not a Case

On its fair banking page, the OCC says many institutions placed restrictions on banking digital asset activities, "including on issuers, exchanges, or administrators," and often attributed the limits to financial crime considerations.

That is the crypto detail in the public material: how the restrictions were justified, not who they hit. The report contains no specific example of debanking tied to digital asset activity.

Other sectors are illustrated. The same page describes a February 2023 decision not to serve a public education organization, a February 2021 account closure for a MAGA merchandise merchant, and restrictions on financing for coal mining, Arctic oil and gas, firearms, detention facilities, and tobacco and e-cigarettes.

The pattern is a category named, a cause given, and no case to check it against.

Gould's Examples Stop at Coal and Firearms

Comptroller Jonathan V. Gould's remarks on 14 October, delivered in Lexington, Kentucky, used the industries the report could show:

"We found that all of these banks had adopted reputation risk policies at various levels which allowed political considerations, public opinion, and social pressures to influence who banks deemed not worthy to access financial services."

Two cases he described involved firearms. One bank denied a firearms business assistance with an initial public offering because the company's policies governing lawful firearms sales did not align with the bank's own standards. Another declined a loan of less than $50,000 to a small firearms-related business. He said the industries particularly affected were coal and firearms. Digital assets did not come up.

Gould also said the OCC has eliminated reputation risk from its own supervisory framework.

The OCC Says It Will Review Its Own Framework

Gould said the agency will be assessing further changes to the regulatory and supervisory framework for the largest banks, to reduce the likelihood of the practices recurring. The OCC's page says it has taken, or is considering, further rulemaking and changes to its complaint process.

None of that is a live rule yet. A crypto company reading the report learns that digital asset activity sits on a list of sectors banks restricted, that the restriction was often explained by financial crime risk, and that the OCC has published no example of it happening.

The OCC has said it cannot measure how widespread debanking was. On digital assets, it has not shown one instance.