Operation Choke Point 2.0: From Crypto Grievance to Federal Finding
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The OCC found subjective reputation policies across nine major banks that disadvantaged lawful businesses and customers.
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Digital assets were among the six industry categories facing banking restrictions.
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The findings support complaints about crypto debanking but do not prove a coordinated government campaign.
Crypto’s complaints about exclusion from the banking system have gained federal backing. The Office of the Comptroller of the Currency released findings showing that major banks used subjective reputation policies that disadvantaged lawful businesses and customers.
The review covered the nine largest national banks under OCC supervision between 2020 and September 2025.
Investigators examined nearly 100,000 complaints, hundreds of individual decisions, and approximately 420,000 pages of bank documents.
Digital assets appeared among six industry categories facing restrictions. For an industry that describes politically driven banking exclusion as “Operation Choke Point 2.0,” the report provides official evidence of barriers but leaves questions about their causes and scale.
OCC Finds Reputation Policies Across Nine Major Banks
The institutions reviewed were JPMorgan Chase, Bank of America, Citibank, Wells Fargo, US Bank, Capital One, PNC, TD Bank, and BMO Bank.
The OCC said all nine maintained policies that could influence access to banking based on political or religious beliefs or lawful business activities. Its central criticism concerned reputation assessments lacking clear standards and objective measures of risk.
Comptroller Jonathan Gould said the policies allowed “political considerations, public opinion, and social pressures” to influence banking decisions.
The report described banks using negative news searches and advocacy organizations’ opinions when assessing customers.
Some ordinary customers lost their services due to unverified allegations, while certain wealthy clients with substantial negative publicity retained their banking relationships.
Examples crossed political lines. One bank-owned processor closed a merchant’s account selling Trump-branded merchandise. Another bank declined to provide services to an educational organization because its political arm endorsed only Democratic candidates.
The findings suggest a broader problem: access may depend on subjective judgments about controversy rather than on consistent assessments of financial exposure.
Digital Assets Named, but Findings Have Limits
The report identified restrictions affecting digital asset issuers, exchanges, and administrators, which banks often attribute to financial crime considerations.
