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Debanking

Nine banks, a review, and no penalty

The OCC said on Wednesday that all nine of the largest national banks it supervises had policies that could deny or limit services over beliefs or lawful business, digital assets included. It announced no penalty, and its head said he was not confident the banks' own fixes would be enough.

Jonathan Bright · Policy Editor
October 15, 20263 min read
The glass-fronted west entrance of Constitution Center in Washington, with the building's name in steel letters above a row of doorsTim1965, CC BY-SA 3.0, via Wikimedia Commons
Constitution Center at 400 7th Street SW in Washington, which houses the headquarters of the Office of the Comptroller of the Currency, in a 2011 file photograph.Photograph via Wikimedia Commons

The Office of the Comptroller of the Currency on Wednesday published the findings of its review of debanking at the nine largest national banks it supervises, and said that between 2020 and September 2025 all nine had policies that may have led them to deny or limit financial services to Americans because of their political or religious beliefs or lawful business activities, according to the agency's release. The banks are JPMorgan Chase, Bank of America, Citibank, Wells Fargo, U.S. Bank, Capital One, PNC, TD Bank and BMO.

The OCC said broad "reputation risk" policies, which lacked clear standards and objective, risk-based criteria, disadvantaged some customers. It said the banks kept public and non-public policies restricting whole industries: oil and gas exploration, coal mining or coal-powered plants, firearms or ammunition, the construction or operation of detention facilities, tobacco and e-cigarettes, and digital asset activities. The report itself says those restrictions "varied from categorical prohibitions to escalated reviews and approvals before providing access".

The exercise was large. The OCC said it reviewed nearly 100,000 complaints and received about 50,000 documents, running to about 420,000 pages, from the banks. It announced the review in September 2025 and issued preliminary findings in December 2025. Even so, the report says the agency "was unable to quantify on a comprehensive basis the full extent of debanking or alleged debanking actions or the costs to customers", citing the completeness of the banks' responses and how they tracked such decisions.

On crypto the report is brief. It says many institutions restricted banking for digital asset activities, "including on issuers, exchanges, or administrators, often attributed to financial crime considerations". It names no affected crypto firms and gives no count of those refused. It also notes that banks have recently removed or relaxed restrictions affecting industries including firearms, tobacco and digital assets, but says it is "difficult to assess at this stage" whether those changes affect actual decisions.

"Today's report provides irrefutable evidence that the nation's largest banks have denied, debanked and discriminated against customers and lawful businesses," said Comptroller of the Currency Jonathan V. Gould. "Americans should have access to financial services regardless of their beliefs, affiliations, or political views. Fair access to financial services is not a mantra—it is a mandate."

No penalty came with the report, and Reuters reported that the OCC did not indicate any sanctions or punishments were forthcoming. The agency said instead that it is considering actions to stop banks discriminating against customers on the basis of political or religious beliefs and to address the role of reputation risk in bank decisions. "Notwithstanding certain efforts by the largest banks to rein in these practices, I am not confident that they will be enough," Gould said, adding that the OCC "will be assessing further changes to the regulatory and supervisory framework applicable to the largest banks".

The contrast with the day before is plain. On Tuesday the same agency fined Bank of America $750m, the largest penalty in its history, for an anti-money-laundering programme it called deficient, as we reported in our coverage of that action. That case punished one bank for too little financial-crime control. This report faults nine for leaning on loose risk language, and the crypto restrictions it describes were themselves often justified as financial-crime controls.

The regulators' side has already changed. An OCC and FDIC final rule that took effect on 9 June bars the agencies from criticising or taking adverse action against a bank on the basis of reputation risk, and from pushing a bank to close or refuse an account because of a customer's political, social, cultural or religious views or politically disfavoured but lawful business. Some crypto firms are meanwhile seeking national trust charters of their own, a route community bankers are suing the OCC over, as covered in our report on Rain's application.

The report is a finding about the past, not a remedy. It leaves the banks free to decline customers on financial-crime and other risk grounds, and what any further rules for the largest banks would require is not yet known.

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