Preliminary Findings on Debanking Practices
The Office of the Comptroller of the Currency (OCC) has released a preliminary report indicating that the nine largest U.S. banks imposed restrictions on providing financial services to various lawful industries, notably including cryptocurrency firms. This practice, commonly referred to as “debanking,” occurred between 2020 and 2023, during which banks refused to offer services or subjected customers to scrutiny beyond their actual financial risks. The OCC’s findings suggest that banks often debanked industries based on broad classifications rather than an individualized, objective, risk-based analysis.
The OCC is committed to ending efforts that weaponize finance. Read the OCC’s preliminary findings from its supervisory review of debanking activities at the nine largest national banks. https://t.co/pFMi7Rt8khpic.twitter.com/XWfbCheo91
— OCC (@USOCC) December 10, 2025
Comptroller of the Currency Jonathan Gould described the banks’ implementation of these policies as “unfortunate,” emphasizing that it was an inappropriate use of their government-granted charters and market power. The report found that industries facing the greatest difficulty in securing banking services included oil and gas, firearms companies, tobacco and e-cigarette manufacturers, and, critically, cryptocurrency companies. Many banks’ policies were publicly disclosed and tied to environmental, social, and governance (ESG) goals, with some institutions also heightening reviews in response to negative media coverage.
Regulator Responds to House Allegations and Unlawful Debanking
The OCC’s review was initially launched following an executive order to investigate banks for potentially barring customers based on political or religious beliefs, or for engaging in certain activities, such as cryptocurrency. Following the release of a House Financial Services Committee majority staff report alleging a “Chokepoint 2.0” campaign from 2021 to early 2025 to discourage banks from serving digital asset businesses, Comptroller Gould largely concurred with the central premise.
The House report contended that a series of interagency policy statements, supervisory programs, and accounting guidance created legal uncertainty and elevated “reputational risk” for banks that served digital asset firms. The cumulative effect of these actions reportedly resulted in at least 30 account closures and a chilling effect that drove innovation offshore, limiting U.S. consumer access to regulated payment rails. The OCC is now committed to investigating the role of the largest banks in debanking digital asset customers, with a stated intent to hold institutions accountable for any unlawful debanking.
Broader Regulatory Shift Against Reputation Risk
The OCC will remove references to “reputation risk” from its guidance and, with the FDIC, propose eliminating it from supervisory programs. The agency also pledged to ensure financial access is based on objective, risk-based analyses. This shift follows the OCC, FDIC, and Federal Reserve withdrawing previous “crypto risk” statements and issuing a new one in July that reframed risk management without blanket discouragement.
Meanwhile, Sergey Nazarov, co-founder of Chainlink, maintains a firm conviction that decentralized finance (DeFi) currently has about 30% global adoption and is on track to achieve full adoption by 2030. He critically asserts that regulatory clarity, especially from the US government, is the vital catalyst for institutional investors. This clarity is necessary to build confidence, allowing them to deploy significant capital into DeFi protocols. For this mainstream integration to occur, Nazarov underscores the need for crucial advancements in automating compliance and in enhancing infrastructure for efficient capital flows.