Bank Account Crypto Company

SKILL 73: Bank Account for a Crypto Company

Purpose

Getting and keeping a bank account as a crypto-adjacent company. Losing your bank account can kill the company overnight.

The Problem

• Many banks will not bank crypto companies (debanking / "Operation Choke Point 2.0")
• Banks that accept you may close accounts without warning
• Signature Bank, Silvergate, Silicon Valley Bank — the three primary crypto banks — all closed in 2023
• No bank account = can't pay employees, vendors, taxes, or rent

Crypto-Friendly Banks (as of 2025-2026)

Primary recommendation: Mercury + Relay as backup (two banks at different institutions always)

What Banks Want to See

Frame your business correctly BEFORE the application:

Good framing: "We operate a technology platform for AI model evaluation competitions" Bad framing: "We run a crypto prediction market and betting platform"

Never lie. But lead with the technology angle, not the crypto/gambling angle. Bank compliance teams approve or reject based on their first read of your business.

Documentation to prepare:

• Clear compliance plan (AML/KYC program, even if just a written policy)
• Legal opinion on business legality (gaming attorney opinion = gold)
• Financial projections and use of funds
• Directors/officers: clean background, no prior bank closures, no criminal history
• Business description: 1-2 pages max, plain English, lead with innovation not regulation

Maintaining the Account

• No surprises: if you're adding a new product line (especially crypto-adjacent) → tell your bank relationship manager before launch, not after
• Quarterly relationship emails: brief update on compliance, user growth, any regulatory developments
• Transaction patterns: large volume spikes without explanation trigger internal bank SAR reviews and account reviews
• Fund separation: NEVER commingle customer funds with operating funds in same account
• Backup account: always maintain accounts at 2 separate institutions

Crypto-Native Treasury (Reduce Bank Dependency)

• Hold operating reserves in USDC/USDT in self-custodied multisig wallet
• Use on-ramp/off-ramp providers (Bridge, MoonPay) for fiat conversion when needed
• Pay crypto-accepting vendors and contractors in USDC
• Minimize fiat touchpoints: less bank dependency = less debanking risk
• Keep 2–3 months of operating expenses in fiat (bank account) and 3–6 months in USDC

If Your Bank Account Gets Closed

Immediate Actions (do these BEFORE the closure deadline, typically 30 days)

1. Immediately open accounts at 2–3 alternative banks (apply same day)
2. Transfer all funds to the new primary account the moment it's open
3. Update payroll provider (Gusto, Deel) with new account
4. Update all vendor ACH payments
5. Update all subscription services and payment processors

What NOT to Do

• Do NOT continue operating on the closed account after the deadline
• Do NOT wait to find a new bank before telling employees and vendors
• Do NOT assume you can get the account back — plan for permanent closure

Post-Closure

• Understand why the account was closed (ask in writing)
• If crypto-related: restructure how you describe the business to the next bank
• If compliance-related: fix the compliance gap before the next application

Account Structure

This is legal research and intelligence, not legal advice. Consult qualified legal counsel before taking action.