Managing "Debanking" Risk: Maintaining Fiat Rails for Web3 Entities

It is "economically rational" for a bank to fire 1,000 crypto clients to avoid one regulatory fine. "Operation Choke Point 2.0" creates a shadow ban where banks use "risk appetite" as a pretext for closure.

Avoid Trap Codes: 522390 (Credit Intermediation), 523130 (Commodity Dealing). Use Safe Codes: 541511 (Custom Computer Programming), 511210 (Software Publishers). Be accurate: If 90% of activity is coding, classify as software.

Isolate the infection. Structure: Entity A (OpCo) holds zero crypto and pays payroll via a Tier-1 Bank. Entity B (Treasury Co) handles crypto and uses Fintech/Crypto-friendly banks. Treasury wires USD to OpCo as "Inter-company Service Fee."

Tier 1: Stealth TradFi (Chase/Wells) for taxes/rent. Tier 2: Fintech (Mercury/Series) for daily ops. Tier 3: Crypto-Native (Sygnum/FV Bank) for heavy crypto flows. N+1 Redundancy is mandatory.

Don't hide; disclose. Provide a "Compliance Packet" including: Flow of Funds Diagram, AML Policy, Forensics Report (Chainalysis), and UBO List. Treat the bank like an investor.

Pre-Notify for >$50k wires. Never use P2P. Use Stablecoin Intermediaries (Circle Mint) to show "Circle Internet Financial" as the sender instead of a trading exchange.

If all banks fail: 1. EMI Licenses (Revolut/Airwallex). 2. Corporate Credit Cards (Brex/Ramp) for 30-day float. 3. Crypto-to-Card (Request Finance) to pay invoices directly in USDC.

1. NAICS Optimized (Software?). 2. Air-Gap Structure (OpCo vs Treasury?). 3. 3-Tier Redundancy (Active accounts?). 4. Compliance Packet (Ready?). 5. Emergency Rails (Credit cards open?).