BaaS for crypto platforms: what makes these programmes different
Exchanges, brokers and custodians can get embedded accounts and IBANs. The diligence is deeper, the perimeter is tighter, and the design work happens first.
Crypto platforms can get Banking-as-a-Service. The obstacle is not category prohibition, it is that a smaller set of licensed institutions will underwrite the category, and those that do ask harder questions earlier. Knowing the questions in advance is most of the work.
What licensed partners assess
- Licensing status. Your registration or authorisation, in which jurisdictions, and what it permits you to do for whom.
- Source of funds controls. How fiat enters and leaves, how you evidence provenance, and what your blockchain analytics stack actually blocks rather than flags.
- Travel rule handling. Which counterparties you exchange data with and what happens when they do not respond.
- Segregation. Whether user fiat is held in dedicated named accounts or pooled, and how reconciliation is evidenced.
- Geography. Which markets you serve, which you block, and how the blocking is enforced technically.
Why dedicated IBANs matter here
Pooled accounts create an attribution problem: the bank sees your balance, not your users. Dedicated IBANs in the users' own names remove the ambiguity, make reconciliation mechanical and make monitoring meaningful. On crypto programmes this is usually a requirement rather than a preference, and it is a large part of why these programmes are designed rather than configured.
The programme perimeter
Crypto programmes come with a tighter operating perimeter: defined activities, defined markets, agreed volume bands and specified review triggers. Growing beyond the perimeter without telling the partner is the most common way a healthy programme becomes a restricted one. Renegotiate before you exceed it, not after.
Evidence this is placeable
Crosswire has placed a crypto exchange running EUR 100M a month onto a full API-driven programme with dedicated user accounts, cards and real-time settlement, replacing a hard-coded multi-provider setup. The anonymised outcome and its methodology are on the achieved outcomes page.
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Also relevant: payment infrastructure for crypto platforms and what BaaS actually costs.
Written and reviewed by the Crosswire advisory team, which designs and places Banking-as-a-Service programmes for platforms in Europe. Reviewed 15 August 2026.
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Published by Crosswire - financial infrastructure for the businesses others won't bank.