Federal regulators are increasingly adopting a more crypto-friendly, and more formal approach to bank supervision, one that may have important implications for D&O liability.  Following the President’s August 2025 “Guaranteeing Fair Banking” Executive Order (EO), the Office of the Comptroller of Currency (OCC) issued bulletins in September 2025 to curb “debanking”.  This guidance forces banks to base service decisions on objective risk, rather than social or political motives. Guidance that is further reinforced by the February 26, 2026 Federal Register release and proposal to restrict banking officials from forcing banks to cut ties with clients engaging in controversial but lawful activities.