Track 5 · Money and banking · Module 23
Banking and crypto
On-ramps, bank partners, the 2023 bank failures, and the Travel Rule.
- Lessons
- 7
- Reading
- 54 min
- Quiz
- 15 questions
- Pass mark
- 80%
- 1Why crypto companies still need banksWhy do crypto companies still need banks?6 min
- 2On-ramps and off-rampsHow do crypto on-ramps and off-ramps work?7 min
- 3Bank partners and de-riskingWhy do banks close or refuse crypto company accounts?7 min
- 4March 2023: three banks in five daysWhat happened to the crypto-friendly banks in March 2023?9 min
- 5The Travel RuleWhat is the crypto Travel Rule?9 min
- 6US bank regulators change courseHow did US bank regulators change their approach to crypto?8 min
- 7Running a crypto company's bankingHow can a crypto company think about its banking risks?8 min
The case used in this module
Each module tells its own made-up Brindlecove story, so details can differ from one module to the next.
Key words
- On-ramp and off-ramp
- An on-ramp swaps ordinary money for crypto. An off-ramp swaps crypto back into ordinary money.12
- Virtual asset service provider (VASP)
- The FATF's name for a business that, for customers, exchanges, transfers or keeps virtual assets, among other services.1
- Customer due diligence (CDD)
- The checks a bank or exchange runs on a customer: who they are, who owns them, why they want the account, and ongoing monitoring.13
- Beneficial owner
- For a US bank's company customer: each person who owns 25% or more of the company, plus one person who controls or manages it.4
- Correspondent banking
- When one bank holds deposits for other banks and provides payment services to them.5
- De-risking
- Ending or restricting relationships with whole groups of customers to avoid risk, instead of managing each customer's risk.67
- Deposit insurance
- Protection for bank deposits if a bank fails. The FDIC's standard limit is $250,000 per depositor, per insured bank, for each account ownership category.8
- Uninsured deposits
- Money in a bank above the deposit insurance limit. Its owner may not get it all back if the bank fails.89
- Systemic risk exception
- The special decision in March 2023 that let the FDIC protect all depositors of Silicon Valley Bank and Signature Bank, insured or not.1112
- Travel Rule
- The FATF's wire transfer rule applied to crypto: details about the sender and receiver must pass between the providers handling a transfer.1314
- Self-hosted wallet
- A crypto wallet not held by a service provider for its owner. The FATF calls it an unhosted wallet; EU law calls it a self-hosted address.1315
- Fedwire
- The US Federal Reserve's system for large, time-critical payments between banks with a Fed account. A payment is final once processed.16
- ACH
- A US network through which banks send each other batches of electronic payments, such as payroll.17
- SEPA
- The Single Euro Payments Area, which lets people make euro payments across 41 European countries as easily as at home.18
- Reputation risk
- The risk that something a bank does could hurt how the public sees it, for reasons not clearly tied to its financial condition.19
- International Standards on Combating Money Laundering and the Financing of Terrorism & Proliferation: The FATF Recommendations. Financial Action Task Force (FATF), updated June 2026, 2012-2026.
- Application of FinCEN's Regulations to Certain Business Models Involving Convertible Virtual Currencies (FIN-2019-G001). Financial Crimes Enforcement Network (FinCEN), US Department of the Treasury, 9 May 2019.
- 31 CFR 1020.210: Anti-money laundering program requirements for banks. Electronic Code of Federal Regulations (US Department of the Treasury, FinCEN rules), read 22 October 2026.
- 31 CFR 1010.230: Beneficial ownership requirements for legal entity customers. Electronic Code of Federal Regulations (US Department of the Treasury, FinCEN rules), read 22 October 2026.
- Correspondent banking. Committee on Payments and Market Infrastructures (CPMI), Bank for International Settlements, July 2016.
- FATF clarifies risk-based approach: case-by-case, not wholesale de-risking. Financial Action Task Force (FATF), 23 October 2014.
- The Department of the Treasury's De-risking Strategy. US Department of the Treasury, April 2023.
- Understanding Deposit Insurance. Federal Deposit Insurance Corporation (FDIC), read 22 October 2026.
- Internal Review of the Supervision and Closure of Signature Bank. New York State Department of Financial Services (DFS), 28 April 2023.
- Review of the Federal Reserve's Supervision and Regulation of Silicon Valley Bank. Board of Governors of the Federal Reserve System, with a cover letter from Vice Chair for Supervision Michael S. Barr, April 2023 (released 28 April 2023).
- Joint Statement by the Department of the Treasury, Federal Reserve, and FDIC. US Treasury Secretary Janet L. Yellen, Federal Reserve Board Chair Jerome H. Powell and FDIC Chairman Martin J. Gruenberg (FDIC press release), 12 March 2023.
- FDIC Acts to Protect All Depositors of the former Silicon Valley Bank, Santa Clara, California. Federal Deposit Insurance Corporation (FDIC) press release, 13 March 2023.
- Updated Guidance for a Risk-Based Approach: Virtual Assets and Virtual Asset Service Providers. Financial Action Task Force (FATF), October 2021.
- Virtual Assets: Targeted Update on Implementation of the FATF Standards on Virtual Assets and Virtual Asset Service Providers. Financial Action Task Force (FATF), July 2026.
- Regulation (EU) 2023/1113 on information accompanying transfers of funds and certain crypto-assets (recast). European Parliament and Council of the European Union, Official Journal L 150 (read on EUR-Lex), 31 May 2023.
- Fedwire Funds Services. Board of Governors of the Federal Reserve System, read 22 October 2026.
- FedACH Services. Board of Governors of the Federal Reserve System, read 22 October 2026.
- Single Euro Payments Area (SEPA). European Central Bank, read 22 October 2026.
- Agencies Issue Final Rule to Prohibit Use of Reputation Risk by Regulators (FIL-13-2026). Federal Deposit Insurance Corporation (FDIC) Financial Institution Letter, 7 April 2026.