Bialosky Assigned to Crypto Case
XXXXX@FDIC.gov; Gekas, JoAnna A. XXXXX@FDIC.gov
Subject: FW: XXXXX XXXXX
FYI – This matter is assigned to Senior Regional Attorney Adam Bialosky.
Adam, XXXXX
From: Sano, Joseph J. XXXXX@FDIC.gov
Sent: Thursday, July 21, 2022 4:03 PM
To: Bialosky, Adam L. XXXXX@FDIC.gov
Cc: Kwong, Kitty XXXXX@FDIC.gov
Subject: FW: XXXXX XXXXX
New Assignment
Crypto
From: XXXXX
Sent: Wednesday, July 20, 2022 11:11 AM
To: Gekas, JoAnna A. XXXXX@FDIC.gov; Sano, Joseph J. XXXXX@FDIC.gov
Cc: Valderrama, Jaclyn M. XXXXX@FDIC.gov
Subject: XXXXX XXXXX
Hello Joe and JoAnna,
Please assign an attorney to XXXXX, which is listed in XXXXX. The bank is not heavily involved in crypto-related activity and the President has stated intentions to reduce any deposits related to crypto. The next examination of the bank is scheduled for 8/15/22.
When questioned about the bank’s crypto related accounts in October 2021, FSI XXXXX provided the following information after speaking to President XXXXX and BSA Officer XXXXX about the bank’s digital asset/crypto related high risk customers in an attempt to better understand that bank’s strategic plan and activities related to this area:
President XXXXX adamantly made clear that the bank has no intention or strategy to seek out or attract digital asset related customers. As a matter of fact, the bank is shrinking the bank from these types of customers because it wants to be a “plain vanilla, traditional style” bank and serve the XXXXX. XXXXX pointed out that virtually all of the customers that have related digital/crypto activity were onboarded in 2020 and were brought into the bank through a relationship they had with the bank’s XXXXX. XXXXX When it became apparent that the bank had no intention to grow this type of business, XXXXX XXXXX resigned to join a start-up FinTech company. To make sure that I fully understood and had on record what the bank’s current crypto-related customer base is, I asked them to provide me with a summary report listing each customer relationship, a description of the customer’s business and activities, and deposit activity.
Three of the bank’s known high-risk customers that are potentially related in some way to digital currency, blockchain, or crypto:
XXXXX
XXXXXXXXXXXXXXXXXXXXXXXXXXXX
Thanks,
XXXXXXXXXX
Case Manager, Division of Risk Management Supervision
Federal Deposit Insurance Corporation
25 Jessie Street at Ecker Square
San Francisco, CA, 94105
XXXXXXXXXX
XXXXXXXX
Concentrations
| LARGE DEPOSITOR* FUNDING CONCENTRATION | BALANCE ('000 USD) | PERCENT OF TOTAL ASSETS |
|---|---|---|
| Large Depositors | XXXXX | XXXXX |
* Large depositors are defined as depositors with balances of two percent or more of the bank's total deposits. Total deposits were XXXXX at June 30, 2022.
\ Total assets were XXXXX at June 30, 2022.
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