CRYPTO/OR/NOT
In buildCrypto exposure intelligence for fiat rails
Crypto flow is on your rails. Your monitoring cannot see it.
Crypto or Not classifies the counterparties in your wires, ACH, and card flows as crypto businesses: what they are, how risky they are, and the evidence behind every attribution. Built for BSA and AML teams, delivered into the systems you already run.
Counterparty classification
Illustrative sample
MERIDIAN DIGITAL MARKETS LLC
CRYPTO · 97WireOTC trading desk4 evidence sourcesNORTHSTAR KIOSK SERVICES INC
CRYPTO · 92ACHCVC kiosk operator3 evidence sourcesBLUEPEAK PAYMENT SOLUTIONS
CRYPTO · 88WireProcessor settling for an exchange5 evidence sourcesHARBORVIEW LOGISTICS INC
NOT CRYPTO · 99ACHFreight and warehousing2 evidence sources
The gap
Today this question is answered with keyword lists, one card code, and customer self-declaration
$8.82T
Stablecoin transfer volume in the first half of 2026, more than all of 2024 combined. Every mint, redeem, and ramp settles over bank rails. Source
$150
The average threshold at which traditional financial institutions now alert on crypto exposure. Banks are already doing this work, with tools that were not built for it. Source
25 to 35
Sponsor banks under consent orders in 2024 and 2025. A 2026 OCC order faults a sponsor bank for not understanding the transactions flowing through its payment processing line. Source
Why now
Regulators opened the gates and kept the obligations
March 2024
Mastercard shuts down CipherTrace Armada, the only product ever built to identify crypto counterparties in bank fiat data. The position is never refilled. Source
March to May 2025
OCC Interpretive Letters 1183 and 1184, FDIC FIL-7-2025, and Federal Reserve rescissions permit bank crypto activities without pre-approval. BSA expectations stay fully in force. Source
July 2025
The GENIUS Act is signed. Payment stablecoin issuers become Bank Secrecy Act financial institutions with full AML program obligations. Source
August 2025
The Fair Banking executive order prohibits debanking lawful businesses. Exiting crypto customers stops being a compliance strategy; identifying and risk-rating them is what remains. Source
January 2026
Basel SCO60 capital treatment and DIS55 disclosure templates take effect. Banks under the standard must quantify and publish their crypto exposure. Source
February 2026
New OCC community bank BSA/AML examination procedures take effect. Risk assessments must reflect the customers a bank actually has. Source
April 2026
FinCEN and OFAC propose AML rules for stablecoin issuers that treat advanced monitoring technology as a mitigating factor in enforcement. Source
The product
Three layers on one classification dataset
Exposure Assessment
Months of wire, ACH, and card settlement data in. A board-ready, examiner-ready digital asset exposure assessment out. Built for the exam request, sized for the thousands of institutions that will never buy a blockchain analytics seat.
Monitoring feed and API
Ongoing counterparty classification delivered into the monitoring stack you already run: Verafin, NICE Actimize, Unit21, Abrigo, Feedzai. We feed your system. We do not replace it.
Agent tools
The classifier exposed as a callable tool over the Model Context Protocol, built for AI-native AML platforms whose agents need a crypto-or-not answer on every alert they triage.
How it works
A registry of crypto businesses, mapped to what they look like on fiat rails
Step 1
The registry
Exchanges, kiosk operators, OTC desks, payment processors, and stablecoin issuers, each mapped to their fiat observables: legal names, DBAs, processor aliases, ACH company identifiers, and descriptor patterns. Not wallet addresses. The things that actually appear in your transaction data.
Step 2
The matching
Entity resolution tuned for payment text rather than web text: normalization, alias expansion, descriptor parsing, and calibrated confidence on every match. Batch over history or streaming over live flow.
Step 3
The evidence
Every attribution carries provenance: the source, the date it was observed, the confidence, and its review status. Built to survive an examination, because attribution a bank cannot defend is worse than none.
Market history
This category had exactly one product. It is gone.
CipherTrace Armada mapped crypto businesses to names and account numbers so banks could find crypto flow in their own data. Mastercard shut it down in March 2024 after the underlying data was described in court as unverifiable and unauditable. The problem did not go away; the volume crossing bank rails has grown several times over since. What the episode set is the bar: attribution a bank can defend, with evidence, source by source. That bar is the foundation Crypto or Not is built on.
Who it is for
Built for the teams holding the exposure
Sponsor and BaaS banks
Consent orders now cite banks for not understanding the businesses behind their payment flows. Continuous counterparty classification is the control examiners are describing.
Banks entering digital assets
Custody, trading, and stablecoin programs all start with the same supervisory question: what crypto exposure is already moving over your rails?
Stablecoin issuers
The GENIUS Act made issuers BSA financial institutions. Mint and redeem legs are fiat wires, and they need bank-grade monitoring from day one.
Community bank BSA teams
A defensible exposure assessment, without a six-figure analytics contract or a consulting engagement, whenever the exam letter asks.
Status
Where this stands
Crypto or Not is in active build by a team with large-bank transaction monitoring experience. The Exposure Assessment is the first deliverable, followed by the monitoring feed and the agent tools.
This site is a concept preview. No customers are named because there are none yet, and no metrics are invented. The market facts above link to their sources. Contact details arrive with the public launch; if you have found this page early and run BSA or AML at an institution that touches crypto flow, we are building this for you.