Debanking, or denying access to financial services, is a nefarious activity that was far too prevalent during the prior administration. Numerous reports indicated that individuals and entities were denied services because of their political leanings or business operations deemed unsavory. Crypto or digital asset firms were frequent targets.
This week, the Office of the Comptroller of the Currency has issued its final report on debanking after months of research. According to the report, it reviewed nine of the largest banks under OCC supervision. In total, the OCC reviewed almost 100,000 complaints between 2020 and September 2025 about restricted access to banking services.
The findings uncovered countless abuses by the firms under review. To quote the report:
The OCC found that, in response to general reputation risk policies, bank employees escalated customers or prospective customers that held potentially contested viewpoints outside the perceived “mainstream” and that those views were often equated with higher potential reputation risk. The OCC found that decisions related to such escalations were not universally consistent across transactions the OCC sampled, illustrating the subjective nature of the banks’ ambiguous and open-ended reputation risk policies and the risks those policies present in denying Americans fair access to financial services. This report highlights several, non-exhaustive examples of Americans that had accounts closed or that were otherwise denied financial services seemingly because of the perceived reputation risks associated with their constitutionally or statutorily protected beliefs, affiliations, or political views. For example, one bank’s payments subsidiary, working with bank reputation risk employees, closed the account of a customer that employees characterized as a “[r]ight wing religious conservative non profit with strong anti LGBTQ rhetoric.” A reputation risk employee later removed references in the internal bank tracking system to the nonprofit organization being “right wing” and “religious.”
Debanking examples provided in the report include:
- One bank closed the account of a merchant that sold merchandise promoting President Trump and the Make America Great Again (MAGA) brand
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One bank declined to provide financial services to a public education organization because of its partisan leanings—specifically, its political arm’s endorsement of only Democratic candidates.
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One bank implemented an environmental and social risk management policy that restricted it from entering into business relationships with customers whose policies did not align with the bank’s responsible firearm standards.
The OCC said that mere allegations could compel a bank to decline services to “average Americans.”
Comptroller of the Currency, Jonathan Gould, commented on the report:
“What began as decisions made by executives to debank disfavored industries became institutionalized and opaque bureaucracies that empowered bank employees to cut off industries and persons from financial services or created procedural frictions that achieved the same result as a practical matter.”
In the end, the regulator said more work is needed to address politicized or unlawful debanking in the federal banking system.
The OCC noted that it continues to review AML/CFT rules that may push banks to err on the side of caution even when a firm is operating legally. Federal agencies are no longer able to point to “reputation risk” as the reason for a bank to deny services.
During the Biden adminstration, which was explicitly anti-digital assets, Operation Choke Point 2.0 was described as using regulatory pressure to shut down crypto firms and cut off access to the banking system. In January 2023, regulators issued a statement warning banks about operational and reputational risks of providing services to digital asset entities. The FDIC issued non-public letters telling banks to stop providing services to these undesirable operations. Today, it appears that blocking financial services due to your business or affiliation, as long as it is not criminal, is no longer the case.
Abuse of federal power is always a risk, especially when the government seeks to expand its authority and control without restraint from the electorate and policymakers.
