Overview
- The study distinguishes political or religious, operational, and government-led account closures, concluding that government involvement explains most documented cases.
- It outlines two channels of government influence: direct pressure through formal letters or orders and indirect pressure via regulation and reputational-risk guidance.
- The report cites FDIC letters urging banks to pause crypto services, which it says functioned as de facto termination notices due to absent timelines or follow-up.
- Crypto firms are presented as frequent targets, with executives such as Jack Mallers and Houston Morgan reporting unexplained closures as Jamie Dimon denies belief-based debanking but notes political pressure on banks.
- Cato recommends that Congress amend the Bank Secrecy Act, end reputational-risk practices, and lift confidentiality that obscures official pressure on financial institutions.