This is not advice. It is a record of how I think about the problems that arrive on my desk. If something here is relevant to a situation you are dealing with, I am available for a conversation.
The instinct after a closure notice is to call a lawyer. In most cases, the problem is not legal. It is architectural — and it was visible in the structure long before the letter arrived.
Even modest cryptocurrency activity can change the entire character of a banking relationship. Not because of what the business does — but because of how the structure reads.
The problems that derail due diligence are almost never legal. They are structural. And by the time the process has begun, the options for addressing them have narrowed considerably.
A bank reviews documents. But what it is actually assessing is whether those documents tell a coherent story. The narrative is not a marketing exercise. It is an architectural one.
A holding company without genuine economic substance is no longer a neutral element in a structure. In the current environment, it is a liability — to banking relationships, to due diligence, and to the tax position it was designed to protect.
De-risking is not a finding that a business has done something wrong. It is a commercial decision by a bank operating under regulatory pressure, applied at the category level, with no implication about the specific conduct of the client caught within it.
I did not come to this work. I was pushed into it by a client with a problem I did not know how to solve. Everything that followed came from that.
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