Crypto Banking & Neobank Solutions

What Is a Crypto Bank or Neobank?

A crypto bank or neobank is a digital-first financial institution that integrates cryptocurrency and digital asset services alongside (or instead of) traditional banking products. Unlike a pure crypto exchange, a crypto bank aims to be the primary financial relationship for its customers — combining fiat accounts, payment cards, crypto wallets, and (for full banks) lending and savings products.

The regulatory structure of a crypto bank is defined by which services it provides:

Neobank vs Traditional Bank: What Licence Do You Need?

The critical distinction is whether you take deposits and whether you lend. These two activities define whether you need a banking licence or can operate as an EMI:

Top Jurisdictions for Crypto Banking

Only a handful of jurisdictions have the regulatory frameworks mature enough to support a full-service crypto banking operation:

Crypto Neobank Product Architecture

A competitive crypto neobank in 2025 typically combines the following product layers:

• Fiat banking layer: Multi-currency IBAN accounts (EUR, USD, GBP, CHF), SEPA/SWIFT transfers, payment cards (Visa/Mastercard debit). Enabled by EMI licence.
• Crypto wallet layer: Self-custodial or custodial wallets for BTC, ETH, stablecoins and top altcoins. Enabled by VASP/CASP registration.
• Conversion & exchange layer: In-app crypto/fiat exchange at mid-market rates or with spread. Enabled by VASP exchange licence.
• DeFi integration layer: Access to staking yields, liquidity provision, lending protocols. Regulatory framework still developing — requires careful structure under MiCA.
• Stablecoin layer: Native stablecoin (if applicable) or support for USDC/EURC. EMT issuer authorisation required under MiCA for EU-facing stablecoin issuance.

Regulatory Pathway: Crypto Neobank Launch

The typical regulatory pathway for a crypto neobank in the EU looks like this:

1. 1

   Jurisdiction & Licence Strategy

   Select primary jurisdiction (Lithuania most common for EU). Determine: EMI-first vs banking charter; which VASP activities; stablecoin plans; target markets.

2. 2

   Entity Formation & Corporate Structure

   Incorporate in target jurisdiction. Establish governance (board, senior management, AML officer, internal auditor). Shareholder structure must satisfy fit-and-proper requirements.

3. 3

   EMI / VASP Application Preparation

   Draft business plan, AML/CFT policy, risk management framework, outsourcing agreements, IT security documentation. EMI application: 200–400 pages of documentation.

4. 4

   Regulator Submission & Review

   Submit application to Bank of Lithuania (or equivalent). Review period: 3–6 months for EMI, up to 12 months for banking charter. Respond to RFIs from regulator within 10 working days.

5. 5

   Banking & Infrastructure Setup

   Open correspondent banking accounts. Integrate card programme (Visa/MC). Set up blockchain node infrastructure or connect to custody provider. Implement AML transaction monitoring.

6. 6

   Soft Launch & Scaling

   Launch with limited beta users. Prove AML controls and transaction monitoring. Seek VASP registration in additional EU member states. Begin EU passport notification for expansion markets.

Crypto Banking Compliance Essentials

Crypto neobanks operate under the most demanding compliance environments in financial services — combining traditional banking AML requirements with crypto-specific FATF Travel Rule and MiCA obligations.

Core compliance requirements for crypto neobanks:

• Full KYC/KYB: Identity verification with liveness detection. Enhanced due diligence for high-risk customers, PEPs, and business accounts.
• FATF Travel Rule: Originator/beneficiary data on all crypto transfers ≥ €1,000. Use IVMS101 standard. Integrate with VASPg, OpenVASP or Notabene for counterparty VASP verification.
• Blockchain analytics: Real-time transaction screening on all crypto flows. Chain analysis integration mandatory for banking partner relationships.
• Safeguarding: EMI directive requires client funds segregated from own funds and covered by safeguarding arrangements. Crypto client assets must be held in clearly segregated wallets.
• Capital adequacy: EMIs must maintain minimum own funds of €350K at all times plus a percentage of payment volume. Monthly regulatory reporting to national competent authority.

Crypto Banking Case Studies

The crypto banking market has produced several notable licence-holders whose structures offer useful precedents:

How We Help Build a Crypto Bank

CryptoLicenses.net works with founders, family offices and financial groups building crypto banking infrastructure. Our services include:

• Licence strategy: EMI vs banking charter vs SPDI — matching your product vision to the right regulatory framework
• Jurisdiction comparison: Lithuania, Switzerland, Singapore, UK — capital requirements, timelines, banking access
• Application preparation: Full documentation package for EMI, banking charter or VASP/CASP authorisation
• Governance structuring: Board composition, senior management fitness, AML officer appointment
• Banking partner introductions: Correspondent banking for crypto neobanks in Europe and Singapore
• MiCA transition: CASP authorisation pathway for existing VASP-registered businesses

Frequently Asked Questions