In a landmark shift, U.S. federal regulators—the OCC, FDIC and Federal Reserve—have reversed course on crypto-related restrictions for banks. As of April 2025, financial institutions no longer need approval to engage in permissible crypto-asset activities. While this move is being heralded in some corners as a green light for crypto engagement, it’s more accurately a shift in regulatory posture—placing a heavier burden on financial institutions to self-govern, manage risk, and ensure safety and soundness.
At SolomonEdwards, we see this as a clarion call for accountability—not a reprieve.
The Opportunity and the Obligation
The absence of explicit interagency restrictions does not equal a lack of regulatory scrutiny. Banks and financial institutions that choose to engage with crypto-asset products and services now bear full responsibility for establishing and maintaining robust governance, operational risk management and compliance frameworks.
Whether you’re building partnerships with digital asset firms, exploring custody services or investing in tokenization, your governance model must evolve to meet the complexity, velocity and financial crime risk inherent in crypto markets. While current Bank Secrecy Act (BSA) requirements offer some prescriptive guidance, institutions must customize and enhance existing regulatory guidance for the complexities of crypto.
In this new environment, major U.S. banks are already moving quickly. In fact, 21% of institutions are active in crypto, and over three-quarters are planning to expand their digital asset strategies in the coming year.
Why It Matters More Now
The recent withdrawal of the 2023 joint statements shifts the risk calculus for boards and compliance leaders. The regulatory agencies have made it clear: Permissible activities remain subject to all existing laws and standards. However, the path forward is now defined by your institution’s ability to design and defend its governance frameworks—especially in areas where the regulatory regime has yet to catch up with the innovation and technology.
We’re already seeing increased expectations around Know Your Customer (KYC), anti-money laundering (AML) protocols and third-party risk management. In this paradigm shift, the most competitive financial institutions will be those that pre-emptively build the governance muscle to support crypto-asset operations safely and sustainably. This requires an internal control framework that demonstrates maturity, foresight and resilience.
How SolomonEdwards Can Help
Our team of former bankers, regulators and financial crime experts specialize in helping financial institutions operationalize emerging regulatory expectations and translate ambiguity into actionable frameworks. We help you:
- Design scalable governance and risk management frameworks for crypto-related operations
- Assess and strengthen AML/KYC protocols and vendor risk oversight
- Integrate digital asset activities into your existing compliance and reporting infrastructure
- Prepare for future guidance by building agile systems and internal accountability mechanisms
We’ve done exactly this for clients navigating crypto-asset risk exposure in complex M&A scenarios.
Read how we helped a U.S. commercial bank accelerate AML integration following a crypto and fintech acquisition.
Accelerating AML Integration for a Crypto and Fintech Acquisition
This is not just about crypto, though. It’s about proving your institution can thrive in a fast-evolving financial environment; one where regulators expect clarity, consistency and competence—even in uncharted territory.
Turn Regulatory Uncertainty into Competitive Advantage
In a time when the rules are still being written, we can help you write your own playbook—one that meets today’s expectations while anticipating tomorrow’s. Get in touch to learn more about preparing to engage in crypto activities with confidence.
About the Author
Partner, Financial Crimes Advisory
Jon Glass has more than 25 years’ experience managing and operating anti-money laundering (AML) compliance, fraud detection and security programs across multiple industries. He was previously a managing director and co-founder of Dominion Advisory Group, a U.S.-based AML advisory and financial crime consulting firm.
Jon has expertise in overseeing the re-engineering of financial intelligence units (FIUs) for domestic and international banks under regulatory enforcement action. He has worked with banks with asset sizes between $1 billion and $2.5 trillion to advise executive management and boards on navigating the onerous requirements of AML and Bank Secrecy Act (BSA) enforcement actions. Jon has advised and overseen remediation efforts focused on training investigative staff, implementing and optimizing transaction monitoring systems, designing case management programs, and improving analysis and investigation quality.
