The market for crypto neobanks and card services is on the verge of a massive purge. My analysis shows that most projects will not survive the next year and a half. And it's not about a lack of demand — $245 million in top-ups over the last week proves the opposite. The root of the problem lies in a fragile and poorly thought-out compliance architecture.
The Three-Way Trap of Cards and Ramps
A card program is a complex triangle: the service, the issuer, and the payment network. Each participant holds a veto right. As soon as trust is lost with one party, cards stop working not gradually, but instantly. The history of Binance is a clear example: in July 2023, Visa left Europe, and two months later, Mastercard left Latin America. In June 2026, the service Ready gave users outside the EEA just one hour to withdraw funds after breaking ties with the issuer.
Payment networks require continuous, not periodic, screening against sanctions lists at the account level. A real transaction monitoring system with instant alerts and unified, strict KYC across all jurisdictions is not a luxury but a necessity. The £29 million fine for Starling Bank due to a six-month absence of individual sanctions notifications is just the tip of the iceberg.
Earn Products: A Legal Time Bomb
The most underestimated but critical layer is earn products. Shared vaults are perceived as a technical solution, but in reality, they are a pure legal problem. Mixing user funds in a single pool creates fiduciary risks and turns the bankruptcy process into a nightmare. If a regulator or banking partner asks, "Show me the ledger entry for a specific user's balance," and the answer requires reconstruction from a shared pool, then there is essentially no answer.
The only correct path is isolating each user's account from day one: a separate ledger entry and individually calculated yield. In Europe, Article 50 of the MiCA regulation directly prohibits paying interest on euro-denominated stablecoins, so the legal route lies through tokenized government bonds and RWA wrappers.
Screening as the Foundation for Survival
The basic layer of the entire structure is screening. Most teams implement it reactively: when something breaks or a regulator asks an uncomfortable question. This is a fatal mistake. Those who survive build compliance proactively: before the card, before the ramp, and before the earn product, with a single, end-to-end audit trail. Disparate point solutions create gaps: KYC does not communicate with transaction monitoring, and that does not feed data into sanctions screening. Each such gap turns into a reconciliation problem at the worst possible moment.
My professional opinion: The $245 million in top-ups is not a story about cards or yield. It is a story about survival. The lessons from WaveCrest, Wirecard, FTX, Binance, and Ready are the same: compliance is not the last thing you build, but the only thing that allows you to build everything else. The market faces a harsh consolidation, and only those who have learned this lesson will survive.