The neobank and crypto card market is on the verge of a major shakeout. My analysis shows that most projects will not survive even a year and a half. The reason is not a lack of demand, but a catastrophically weak compliance architecture. This is not just a bureaucratic formality, but the foundation on which the entire business rests.
Over the past week, the volume of crypto card top-ups has reached a record $245 million. These figures clearly demonstrate that the problem is not with the clients—demand is enormous. The issue lies in what is hidden "under the hood" of most services. Having studied compliance infrastructure since 2017, I see that the market rests on several technical layers, and the failure of any one of them can instantly collapse the entire business.
Why cards and ramps are primarily about compliance
A card program is 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. As soon as any party loses trust in the system, cards stop working not gradually, but instantly. Recall Binance, which lost Visa in Europe in July 2023, and two months later, Mastercard in Latin America. Or the service Ready, which in June 2026 gave users outside the EEA just one hour to react when relations with the issuer were severed.
Payment networks require continuous, not periodic, screening against sanctions lists at the individual account level. A transaction monitoring system with real-time alerts and a secure KYC layer across all operating jurisdictions is necessary. The cost of error is colossal: the £29 million fine for Starling Bank over a system that failed to generate a single individual sanctions alert for six months is a stark example.
The on/off ramp layer deserves special attention. Each such step is first a compliance event and only then a matter of convenience. On-ramps verify the source of funds and identity, while off-ramps critically require a clean audit trail with documented source of funds. It is on the off-ramp process that teams most often cut corners, assuming users won't notice. But regulators and banking partners do notice. During a quarterly review, the bank takes a sample of transactions, and if the "trail is not clean" for each transaction, the company finds out at the worst possible moment.
Why yield products and compliance solve everything
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 the pool's accounting, then there is essentially no answer.
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, incidentally, Article 50 of the MiCA regulation prohibits paying interest on euro-denominated stablecoins, so the legal path lies through tokenized government bonds and "RWA wrappers."
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 fundamentally 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, which in turn does not pass data to sanctions screening. Each such gap turns into a reconciliation problem at the most inopportune moment.
My professional opinion: $245 million in top-ups is not a story about cards or yield, it's a story about survival. Compliance is not the last thing you build, but the only thing that allows you to build everything else. The lesson taught over the years by WaveCrest, Wirecard, FTX, Binance, and Ready has not been learned by everyone. The market is heading for a harsh consolidation, and only those who understood this first will remain.