Which Banks Are Moving Into Crypto | US Banking Regulations & XRP Adoption | XRP Academy - XRP Academy
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intermediate50 min

Which Banks Are Moving Into Crypto

Learning Objectives

Identify which major banks have announced crypto initiatives

Analyze bank implementation strategies across different institution types

Distinguish between announced plans and operational reality

Assess bank decision factors for crypto engagement

Evaluate implications for XRP institutional adoption timeline

In financial services, there's often a significant gap between announcement and execution. A bank may announce "exploring blockchain solutions" while having no operational capability. Understanding this gap is critical for evaluating the actual state of bank crypto adoption.

  1. What have they **announced**?
  2. What are they **actually doing**?
  3. What **services** are operational?
  4. What **assets** are covered?
  5. What **clients** can access services?
  6. What **timeline** for expansion?

This rigorous approach separates marketing from operations—essential for investment analysis.


  • World's largest custodian (~$50 trillion AUC)
  • Founded 1784
  • Core business: custody, asset servicing, clearing
  • October 2022: Launched crypto custody (Bitcoin, Ethereum)
  • 2023-2024: Cautious expansion during restrictive period
  • July 2025: Announced RLUSD custody partnership with Ripple
  • 2025: Expanding asset coverage

Current Operational Status:

BNY MELLON CRYPTO CAPABILITIES (NOVEMBER 2025)

CUSTODY:
├── Bitcoin: Yes (operational)
├── Ethereum: Yes (operational)
├── XRP: Not confirmed publicly
├── RLUSD: Yes (announced partnership)
└── Other assets: Expanding

CLIENT ACCESS:
├── Institutional only
├── Qualified institutional buyers
├── Asset managers, funds, pensions
└── Not retail

INFRASTRUCTURE:
├── Sub-custody via Fireblocks
├── Integrated with traditional custody platform
├── Single statement, multiple asset types
└── Institutional-grade security

SERVICES:
├── Custody (holding)
├── Safekeeping
├── Reporting
└── Execution: Limited/evolving

XRP Relevance:
BNY Mellon's Ripple partnership positions it for XRP-related services. RLUSD custody is confirmed. XRP custody expansion would be logical next step but not confirmed.

  • Second-largest custodian globally
  • ~$44 trillion AUC
  • Strong institutional client base
  • 2019: Digital asset division announced
  • 2020-2021: Pilot programs
  • 2022-2024: Slowed during restrictive period
  • 2025: Advancing digital asset capabilities
  • Digital asset custody capabilities in development
  • Less aggressive than BNY Mellon
  • Focus on tokenized assets alongside crypto
  • Timeline for full services unclear
  • Major institutional custodian
  • Strong in alternatives, private markets
  • Partnered with Standard Chartered on Zodia Custody
  • International focus (UK-based Zodia)
  • US expansion plans unclear
  • Less visible in US crypto custody

  • Largest US bank by assets
  • Dominant in investment banking, trading
  • CEO Jamie Dimon: Famously critical of Bitcoin

Crypto Reality:
Despite Dimon's Bitcoin skepticism, JPMorgan has significant blockchain activity:

JPMORGAN BLOCKCHAIN/CRYPTO ACTIVITIES

ONYX (Blockchain Unit):
├── Onyx by J.P. Morgan: Enterprise blockchain platform
├── JPM Coin: Internal settlement token (since 2019)
├── Tokenized collateral: Repo market applications
└── Blockchain-based payments

CLIENT SERVICES:
├── Does NOT offer crypto custody for clients
├── Does NOT offer crypto trading for clients
├── Does facilitate some institutional crypto access
└── Cautious public posture despite private activity

PARTNERSHIPS:
├── Various blockchain technology partnerships
├── Enterprise focus, not retail crypto
└── Internal use cases prioritized
```

Assessment:
JPMorgan is blockchain-active but crypto-cautious. They use blockchain internally (JPM Coin) but haven't launched client-facing crypto custody or trading. Conservative approach despite technical capability.

  • Second-largest US bank
  • Major retail and commercial presence
  • Filed significant blockchain patents
  • Limited operational crypto services
  • Traditional approach to implementation
  • No major crypto custody announcement
  • Global bank with strong institutional presence
  • Active in innovation initiatives
  • Citi Token Services (tokenization focus)
  • Digital asset custody exploration
  • 2025: Some service announcements
  • Less aggressive than BNY Mellon
  • Fourth-largest US bank
  • Primarily retail/commercial focus
  • Limited public crypto activity
  • Conservative approach
  • Regulatory constraints (consent order history)
  • Not a leader in crypto banking

  • 5th largest US bank
  • Strong in payments and processing
  • 2021: Announced crypto custody pilot
  • 2022-2024: Paused during regulatory uncertainty
  • September 2025: Resumed crypto custody services

Current Status:

US BANCORP CRYPTO SERVICES (NOVEMBER 2025)

CUSTODY:
├── Bitcoin: Yes (resumed)
├── Ethereum: Yes (resumed)
├── Sub-custody: NYDIG partnership
└── Client focus: Institutional

SIGNIFICANCE:
├── First major regional to resume post-2025
├── Signal of regional bank confidence
├── Model for other regional banks
└── Validates regulatory environment change
  • 6th largest US bank
  • Strong commercial banking
  • Limited public activity
  • Potential for expansion
  • No major announcements
  • 7th largest US bank (BB&T + SunTrust merger)
  • Limited public crypto activity
  • Traditional approach

  • First federally chartered crypto bank (OCC, January 2021)
  • Qualified custodian
  • Institutional focus
  • Full crypto custody
  • Trading services
  • Staking services
  • Governance services
  • Institutional-only

Significance:
Anchorage demonstrates that crypto-native institutions can obtain federal banking charters. Model for Ripple's bank charter application.

  • Wyoming SPDI charter (2020)
  • Kraken exchange affiliate
  • Wyoming charter operational
  • Limited services compared to full bank
  • Fed master account not obtained
  • New OCC conditional approval (October 2025)
  • Focus on technology companies and crypto
  • De novo national bank
  • First new national bank charter specifically for crypto-focused institution
  • Signals OCC openness to new entrants
  • May inform Ripple application evaluation

  • BNY Mellon: Most advanced, operational crypto custody, RLUSD partnership
  • Anchorage Digital: Full crypto bank, federal charter
  • US Bancorp: Resumed services, regional leader
  • State Street: Building capabilities, slower pace
  • Citi: Tokenization focus, crypto exploration
  • Several others with announced initiatives
  • JPMorgan: Blockchain yes, crypto custody no
  • Bank of America: Patents but limited services
  • Most regional banks: Monitoring situation
  • BNY Mellon → Fireblocks
  • US Bancorp → NYDIG
  • Others → Various crypto-native partners
  • No retail crypto custody at major banks
  • Minimum investment thresholds
  • Qualified purchaser requirements
  • Bitcoin: Nearly universal first choice
  • Ethereum: Usually second
  • Other assets: Later expansion
  1. Custody (holding)
  2. Execution (at client direction)
  3. Trading facilitation
  4. (Prime services—future)
  1. **Client demand:** Institutional clients want unified custody
  2. **Competitive pressure:** Risk losing clients to crypto-native
  3. **Revenue opportunity:** Fee income potential
  4. **Strategic positioning:** Don't get left behind
  1. **Risk aversion:** Reputation, regulatory, operational
  2. **Resource constraints:** Compliance costs, expertise
  3. **Client priorities:** May not be top client demand
  4. **Uncertainty:** Still evaluating landscape

Major Banks Offering XRP Custody:
As of November 2025, no major US bank has publicly confirmed XRP custody services.

  1. **SEC lawsuit history:** Even post-settlement, legacy concerns
  2. **Asset priority:** Bitcoin/Ethereum come first
  3. **Demand question:** Have institutional clients pushed for XRP?
  4. **Ripple relationship:** No direct partnerships announced (except RLUSD)
  • Already partnered with Ripple for RLUSD
  • Logical next step to add XRP
  • Relationship exists
  • Timeline: Possible 2025-2026
  • Institutional clients request XRP custody
  • Banks respond to fee opportunity
  • Multiple banks add simultaneously
  • Timeline: Dependent on demand signals
  • Ripple proactively partners with banks
  • Provides integration support
  • Creates XRP custody ecosystem
  • Timeline: Active Ripple effort needed
  • BNY Mellon adds XRP custody in 2026
  • 2-3 other major custodians follow
  • XRP custody broadly available by 2027
  • Limited XRP custody expansion 2025-2026
  • Gradual adoption through 2027-2028
  • Follows Bitcoin/Ethereum expansion pattern
  • XRP custody remains limited
  • Banks focus on Bitcoin/Ethereum/stablecoins
  • XRP not prioritized by major custodians

  • New crypto custody services
  • Asset expansion (especially XRP)
  • Ripple partnerships
  • Regional bank entry
  • OCC guidance updates
  • Examination feedback themes
  • Fed master account decisions (Ripple)
  • Bank charter approvals
  • Crypto custody AUM figures
  • Institutional inflows to crypto
  • XRP institutional holdings data
  • ETF/fund launches
  • Bank earnings calls and investor presentations
  • Regulatory agency press releases
  • SEC filings (Form 10-K, 10-Q)
  • American Banker
  • The Block
  • Coindesk
  • Bloomberg crypto coverage
  • OCC bulletins and releases
  • Fed announcements
  • FDIC notices

Bank crypto adoption is real but measured. BNY Mellon leads with operational services and the Ripple/RLUSD partnership. US Bancorp's resumption signals regional bank confidence. However, no major bank has confirmed XRP custody. The pattern—Bitcoin first, then Ethereum, then others—suggests XRP custody will follow rather than lead. Ripple's BNY Mellon relationship creates a pathway, but expansion timeline depends on client demand, Ripple business development, and continued regulatory stability.


Assignment: Create a scorecard assessing bank crypto adoption status and XRP relevance for five major banks.

Requirements:

Part 1: Scorecard Template (One Page)

  • Crypto custody operational? (Y/N/In Development)
  • Assets covered
  • Client types served
  • Sub-custodian used
  • Ripple/XRP relationship
  • Recent announcements
  • Assessment (Leader/Active/Watching)

Apply to: BNY Mellon, State Street, JPMorgan, US Bancorp, and one bank of your choice.

Part 2: Detailed Analysis - BNY Mellon (300-400 words)

  • Current capabilities
  • RLUSD partnership specifics
  • XRP custody prospects
  • Competitive position

Part 3: Pattern Analysis (200-300 words)

  • What patterns emerge across banks?
  • What predicts crypto adoption speed?
  • Where does XRP fit in expansion priorities?

Part 4: Investment Implications (150-200 words)

  • How should bank adoption status affect XRP investment thesis?

  • What catalysts would change the picture?

  • What monitoring should investors prioritize?

  • Accuracy of scorecard data (30%)

  • Quality of BNY Mellon analysis (25%)

  • Pattern recognition (25%)

  • Investment reasoning (20%)

Time investment: 2-3 hours
Value: Develops ability to assess institutional adoption status systematically


1. Bank Leadership (Tests Current Knowledge):

Which major US bank has the most advanced operational crypto custody services as of November 2025?

A) JPMorgan Chase
B) Bank of America
C) BNY Mellon
D) Wells Fargo

Correct Answer: C

Explanation: BNY Mellon launched crypto custody in October 2022, has operational Bitcoin and Ethereum custody, uses Fireblocks sub-custody, and announced the RLUSD partnership with Ripple in July 2025. JPMorgan has blockchain activity (Onyx, JPM Coin) but not client crypto custody (A is wrong). Bank of America and Wells Fargo have limited operational crypto services (B and D are wrong).


2. Implementation Pattern (Tests Understanding):

What is the dominant implementation model for bank crypto custody?

A) Banks build proprietary custody infrastructure
B) Banks partner with crypto-native sub-custodians (Fireblocks, NYDIG, etc.) while providing the client relationship and regulatory wrapper
C) Banks outsource entirely to crypto exchanges
D) Banks don't offer crypto custody

Correct Answer: B

Explanation: The sub-custody model dominates: banks provide client relationship, regulatory credibility, and balance sheet strength while crypto-native firms (Fireblocks, NYDIG, BitGo) provide technology and operations. This accelerates deployment without requiring banks to build proprietary infrastructure. Full proprietary build is rare (A is wrong). Banks don't outsource to exchanges (C is wrong). Multiple banks do offer custody (D is wrong).


3. Asset Priority (Tests Pattern Recognition):

In what order do banks typically add crypto assets to their custody services?

A) Stablecoins first, then major cryptos
B) XRP first due to Ripple partnerships, then Bitcoin
C) Bitcoin first, then Ethereum, then other assets
D) All assets simultaneously

Correct Answer: C

Explanation: Banks consistently prioritize Bitcoin (largest, most established) first, then Ethereum (second largest), then expand to other assets over time. This reflects client demand patterns, regulatory clarity (Bitcoin/Ethereum have longest history), and operational pragmatism. Stablecoins may be added early but not before BTC (A is wrong). XRP has not been prioritized first (B is wrong). Sequential rollout is standard, not simultaneous (D is wrong).


4. XRP Custody Status (Tests Specific Knowledge):

What is the current status of XRP custody at major US banks?

A) Multiple major banks offer XRP custody
B) No major US bank has publicly confirmed XRP custody services, though BNY Mellon's Ripple partnership creates a pathway
C) XRP custody is prohibited by regulators
D) All banks that offer Bitcoin custody also offer XRP

Correct Answer: B

Explanation: As of November 2025, no major US bank has publicly confirmed XRP custody. However, BNY Mellon's RLUSD partnership with Ripple creates a logical pathway to XRP custody expansion. Regulators have not prohibited XRP custody (C is wrong). XRP is not automatically included with Bitcoin (D is wrong). Multiple major banks don't yet offer XRP (A is wrong).


5. Adoption Assessment (Tests Analysis):

What factor most strongly predicts whether a bank will move quickly into crypto custody?

A) Bank size (larger banks move faster)
B) Geographic location (East Coast banks lead)
C) Institutional client demand combined with strategic priority from leadership
D) Number of retail customers

Correct Answer: C

Explanation: Bank crypto adoption is driven by institutional client demand (clients want unified custody) combined with strategic leadership commitment (willingness to invest in capabilities). Size doesn't predict speed—regional US Bancorp moved while larger banks waited (A is wrong). Geography doesn't determine adoption (B is wrong). Retail customer base is less relevant since services are institutional-only (D is wrong).


  • BNY Mellon crypto custody press releases
  • US Bancorp investor presentations
  • State Street digital asset communications
  • JPMorgan Onyx documentation
  • American Banker crypto banking coverage
  • The Block institutional crypto research
  • Coindesk bank adoption tracking
  • OCC interpretive letters (1170, 1183, 1184)
  • Fed master account decisions
  • Bank charter approvals (Erebor)

For Next Lesson:
Lesson 14 will examine stablecoin and tokenized deposit competition—how RLUSD competes with bank-issued stablecoins, JPM Coin, and the emerging tokenized deposit market. Understanding this competitive landscape is essential for evaluating RLUSD's positioning.


End of Lesson 13

Total words: ~5,200
Estimated completion time: 50 minutes reading + 2-3 hours for deliverable

Key Takeaways

1

BNY Mellon leads bank crypto adoption.

With operational custody, sub-custody via Fireblocks, and the Ripple RLUSD partnership, BNY Mellon is the most advanced major bank. This relationship creates the clearest pathway to institutional XRP services.

2

Sub-custody model dominates.

Banks partner with crypto-native custodians (Fireblocks, NYDIG, BitGo) rather than building proprietary infrastructure. This accelerates deployment but creates third-party dependencies.

3

Bitcoin and Ethereum come first.

Every major bank prioritizes BTC and ETH coverage before other assets. XRP custody expansion will follow, not lead, this pattern.

4

Gap between announcements and operations is real.

Many banks have "blockchain initiatives" or "exploring crypto" without operational services. Rigorous analysis distinguishes marketing from reality.

5

XRP custody timeline is uncertain but pathways exist.

BNY Mellon expansion, client demand, and Ripple business development could drive XRP custody adoption. But no major bank has confirmed XRP custody—investors should weight this appropriately. ---