Describe the business before requesting an account
FinCEN’s interagency guidance describes risk-based banking due diligence for money services businesses. It includes checking applicable registration and licensing and understanding the risk of the account. A crypto business should therefore explain its actual functions and customer relationships rather than asking whether a bank is simply crypto friendly.
Prepare an ownership chart, management contacts and a plain-language service description. Distinguish company capital, operating revenue and customer money. Give the bank an expected transaction profile with currencies, amounts, counterparties and locations. Identify which services are already operating and which remain dependent on permissions or other launch conditions.
Connect the permission file to money flows
Provide evidence of relevant federal registration and state permissions where applicable, or the documented analysis supporting another position. Explain which legal entity holds each relationship. Do not use an affiliate’s record without clarifying its role, particularly where customer payments enter an account held by a different company.
Attach source-of-funds evidence and describe exchange, custody and payment partners. For proposed customer-money arrangements, ask how account titling, control and reconciliation should work. Clarify which party initiates transfers and who investigates exceptions. These details help a bank assess the account rather than relying on broad sector classifications.
Clarify limits and protection claims
Ask which flows the institution will support and what changes require further review. Save operational answers on counterparties, payment references and expected volumes. Keep evidence current so an unusual transfer can be explained using original records. Account acceptance is an institution-specific decision and does not guarantee each future payment.
Be precise when describing deposit protection to customers or investors. FDIC insurance does not cover crypto assets, and a banking relationship does not turn a platform’s token liabilities into insured deposits. Review the actual account arrangement and avoid promises broader than its terms. Maintain separate records for bank balances and customer crypto obligations.
Sources & scope
Official sources support the jurisdiction context. The working checklists are CryptoGov’s editorial preparation suggestions, not an exhaustive application or filing requirement. Confirm the rules and your circumstances before acting.