The market for crypto neobanks and payment services is experiencing a crisis that is not directly related to a drop in demand. My research shows that the main reason for the high mortality rate of projects is not a lack of customers, but critically weak compliance architecture. More than 80% of such services will not survive the next 18 months.
The problem is not user acquisition. Over the past week, the total volume of crypto card top-ups reached a record $245 million. This proves the market is growing, but the infrastructure "under the hood" cannot withstand the load. I have been studying this field since 2017 and see that collapse does not happen gradually, but instantly—at the moment when one of the key links in the system breaks.
Why cards and ramps are primarily about compliance
A card program involves a three-way relationship between the service, the card issuer, and the payment network (Visa/Mastercard). Enhanced scrutiny from the network is layered on top of the issuer's requirements. If at least one of the parties loses trust in the system, cards stop working not gradually, but instantly.
Prominent examples include Binance, which lost Visa in Europe in July 2023 and Mastercard in Latin America two months later. Or the Ready service, which in June 2026 gave users outside the EEA just one hour to react when its relationship with the issuer was severed.
The payment network requires continuous, not periodic, screening against sanctions lists at the level of each account. A transaction monitoring system with real alerts and a secure KYC level across all operating jurisdictions is necessary. The cost of a mistake is the £29 million fine for Starling Bank over a system that failed to generate a single individual sanctions alert for six months.
Yield products and compliance: a hidden bomb
The most underestimated layer is yield products (earn). Shared vaults are perceived as a product solution, but in reality, they are a legal solution. Commingling user funds in a single pool creates fiduciary risks and complicates the situation in bankruptcy. The "killer question" for such a structure is simple: show the ledger entry for a specific user's balance. If the answer requires reconstruction from pool accounting, there is essentially no answer.
The best practice is to isolate each user's account from day one: a separate ledger entry and individually calculated yield. Only such a structure withstands scrutiny from a banking partner, regulator, or institutional investor. In Europe, Article 50 of the MiCA regulation prohibits accruing interest on euro-denominated stablecoins, so the legal path lies through tokenized government bonds and RWA "wrappers."
The foundation of survival: preventive screening
The foundation of the entire structure is the screening layer. Most teams build it reactively—when something breaks or a regulator asks a question. This is the wrong approach. Those who survive build compliance preventively: before the card, before the ramp, and before the yield product, with a single end-to-end audit trail.
Disparate point solutions create gaps: the KYC system does not communicate with transaction monitoring, and that system does not pass data to sanctions screening. Each such gap turns into a reconciliation problem at the worst possible moment.
My conclusion as an analyst: $245 million in top-ups is not a story about cards or yield; it is a story about survival. Compliance is not the last thing you build; it is the only thing that allows you to build everything else. Those who have not understood this will repeat the fate of WaveCrest, Wirecard, FTX, Binance, and Ready.