Go-To-Market Strategies That Work for New Crypto Neobanks

Crypto neobanks are emerging at a time when traditional banks are retreating from the sector, regulators are raising expectations, and crypto businesses are under pressure to secure stable access to fiat infrastructure. These forces make growth strategy a defining factor in survival, not a secondary concern.

This piece examines how focused positioning, relationship-driven distribution, disciplined licensing choices, and realistic revenue models allow new crypto neobanks to grow credibly, satisfy regulators, and build durable businesses in a constrained and highly scrutinised market.

Traditional banks throughout Europe have been systematically de-risking the crypto sector for over a decade, ultimately denying crypto businesses access to banking altogether.

Where traditional banks do maintain crypto relationships, the larger “correspondent” banks that connect them to the international payments system exert heavy pressure to cut those ties. As a result, these smaller banks are forced into an impossible choice: serve the needs of their crypto customers, or keep their place in the economic infrastructure of civilisation.

Under such conditions, crypto exchanges, blockchain-based ventures, and Web3 companies find themselves perennially unbanked despite legitimate, compliant business operations.

The cost of compliance for any given bank account that handles crypto-related activity is many times higher than the revenue it generates. Those costs mount up when the bank must spend significant sums on:

The income from these accounts only partially offsets these expenses through relatively low fee income.

This cost–revenue dynamic explains why compliant and well-capitalised crypto firms struggle to obtain bank accounts even if they have the resources to do so. Traditional banks ultimately decide they would rather avoid the operational and regulatory burden than serve crypto businesses.

Crypto neobanks should prioritise client segments that combine acute banking needs, high transaction volumes, and a demonstrated capacity to meet compliance obligations.

Crypto exchanges and brokers

Crypto exchanges suffer the most severe access to banking, and yet have a huge source of transaction volume. They also need bank accounts with robust fiat on-ramps and off-ramps. Hence, the banking relationships of exchanges are mission-critical to their operations.

The sheer volume of transactions on an exchange provides sources of revenue for neobanks, including:

Exchanges hold a lot of cash in their account. They also have predictable patterns of activity, which makes them a “safe” source of revenue.

Web3 and blockchain startups

Web3 and blockchain startups have considerable but less severe banking needs, and they understand the compliance obligations of the crypto ecosystem better than most.

Firms such as NFT marketplaces, DeFi organisations, and blockchain infrastructure builders require access to traditional banking systems to:

These firms are often venture capital-funded and will hold large reserves of cash. They also tend to have better financial operations than purely crypto-native firms. Additionally, they are often more compliant than crypto-native firms, as they have faced compliance inquiries from their investors.

Trading firms, OTC desks, and fintech platforms

OTC desks conduct massive payment flows in their trading of crypto assets between their clients and other market participants. They also have the potential to generate huge amounts of revenue through transaction fees and foreign exchange spreads.

Resources at these desks include sophisticated compliance teams that onboard their clients and retain records of all transactions. In many ways, they remain “lower risk” clients for neobanks despite their focus on crypto transactions.

Other potential clients for crypto neobanks include FinTech platforms that offer crypto functionalities. These are typically licensed entities that demonstrate readiness for regulation. Both B2B and B2C clients provide neobanks with the revenue concentration and operational sophistication necessary to make their businesses profitable.

In crypto neobanking, business (B2B) accounts are a significantly greater source of early revenue than retail (B2C) accounts. B2B clients generate transaction volumes that are 10 to 100 times greater than those of retail customers, with far fewer accounts required to reach profitability.

A single exchange can generate millions of transactions each month, and these transactions produce significant fee income for the neobank. The volume of money B2B clients hold in their accounts also allows a neobank to cover its fixed costs much more quickly than by working with retail clients alone.

These fixed costs include:

B2B clients will also tolerate a higher fee structure than retail clients. They understand both the value of a reliable, crypto-friendly banking infrastructure and how rare such services are.

Business clients can also be expected to submit to rigorous due diligence processes when opening an account. They provide documentation that retail clients do not (or cannot) provide on demand, and they often come equipped with professionally staffed compliance departments.

Compared with managing thousands of “difficult” retail clients with opaque transaction data patterns, monitoring compliance for 100 business clients is a walk in the park for a neobank.

The same logic applies to customer communication. Communicating with B2B customers entails establishing working relationships with account managers who handle inquiries independently. In contrast, communicating with retail clients requires building scalable, chatbot-based systems capable of addressing queries from thousands of users.

The “crypto is for everyone” positioning fails because trying to serve everyone at once dilutes compliance capabilities, fragments product development, and results in an unbounded value proposition.

Neobanks that attempt to target every market segment—from retail consumers to professional traders, institutional clients to merchants, and even other fintechs—require distinct compliance processes, risk models, and support infrastructures. The resulting operational complexity is far too much for an embryonic organisation and its regulators.

Regulators are highly suspicious of would-be crypto banks that cast a wide net. They rightly doubt these institutions’ ability to spot and manage the diverse transaction patterns and risk profiles of their customers.

Focusing on a niche allows crypto neobanks to build expertise in their customers’ behaviour patterns, typical transaction flows, and red flags. A neobank that only services exchanges, for example, understands the workings of an ordinary exchange very well.

Its compliance team knows:

This enables the development of efficient monitoring processes that satisfy regulators while minimising false positives. Specialisation also allows for risk models tailored to specific customer bases rather than generic parameters.

From an operational perspective, a focus on a niche allows for optimisation of the banking offering and the creation of a reusable knowledge base for customer support. It also simplifies and sharpens sales positioning. Being perceived as serious by regulators requires no more than signalling that the neobank understands the risks present in the niche and has implemented suitable safeguards.

It only makes sense to move beyond an initial niche after achieving market dominance, operational maturity, and credibility with regulators. In most cases, this requires two to three years of profitable operations with proven compliance capabilities.

Signs that it may be time to diversify include:

Successful crypto neobanks branch out cautiously, targeting adjacent segments with similar risk profiles and operational requirements—for example, exchanges that begin servicing OTC desks before expanding to retail consumers.

Crypto neobanks acquire their first customers through relationship-driven go-to-market strategies and deliberate trust-building in an industry defined by regulatory risk and repeated banking failures.

Go-To-Market Strategies That Are Working

Partnerships and ecosystem referrals deliver the best quality customers, since trusted intermediaries pre-qualify prospects and provide implicit endorsements that accelerate sales cycles.

Neobanks typically partner with crypto infrastructure players such as:

These partners have many customers but little need for bank solutions. This allows neobanks to establish referral channels in which prospective customers already understand the challenges of banking and are actively seeking a solution.

Relationships with partners in trade associations, industry groups, or Web3 accelerators also provide large returns in terms of contact points while lending credibility to the neobank.

Founder-led sales generate most early traction, as crypto banking remains relationship-driven and dependent on personal trust and credibility for conversions. Neobank founders often come from crypto businesses or have experience in traditional financial institutions. They understand the pain points of prospective customers and can communicate solutions in ways hired salespeople cannot replicate.

Active participation in the crypto community—through conferences and industry events—creates organic networking opportunities. The crypto industry is small and tightly interconnected; reputation travels quickly. Good experiences with neobanks spread informally, while bad experiences are shared just as rapidly.

Building Trust in a High-Risk Industry

Compliance transparency has been leveraged as a growth mechanism by converting back-office requirements into a competitive selling point that attracts customers while reassuring regulators.

Rather than keeping compliance opaque like traditional banks, successful neobanks are open about:

This transparency addresses a central concern for crypto businesses: the fear of sudden account termination. Publishing case studies demonstrating regulatory engagement, sharing compliance insights through content, and providing clearly defined documentation requirements all help build confidence.

Customers tend to favour rigorous compliance procedures over neobanks that attempt to bypass operational rigor, as strong compliance signals longevity and reduces the risk of abrupt account closures.

Account management is relationship-driven rather than transactional, allowing neobanks to restore the human element largely abandoned by traditional banking models. Dedicated relationship managers who understand a customer’s business model, transaction patterns, and growth ambitions help rebuild trust over time.

This approach has particular value in a market where many firms have had accounts terminated without explanation. Having a specific person within the bank who understands the business creates meaningful reassurance when issues arise. The relationship-driven model also generates commercial intelligence that informs product development and strengthens long-term retention.

Profitable crypto-friendly banks rely on revenue models that scale with customer activity while minimising balance-sheet exposure. These models prioritise transaction volume, conversion flows, and recurring service fees rather than traditional deposit-driven lending.

Transaction and payment fees

This is the most basic revenue model. The bank makes money on every customer payment, regardless of account balance.

Fees apply to:

Charges are typically structured as a percentage of the transaction or a fixed fee per transaction. Transaction-based revenue aligns bank revenue directly with customer activity: no balance sheet exposure, and higher volumes translate directly into higher revenue.

Payment processing for crypto businesses typically costs 0.5–2% per transaction, compared to 0.1–0.5% for traditional banks, reflecting higher compliance costs. These fees are predictable, recurring, and scale naturally with every new customer.

FX and crypto-to-fiat conversion spreads

This model generates significant revenue by capturing the spread between wholesale and retail access rates.

Crypto businesses frequently convert between fiat and crypto, generating high-frequency transaction volume. Banks aggregate customer flows into large blocks, access wholesale FX and crypto-to-fiat markets at favourable rates, and then charge customers:

Value is captured through spreads rather than transaction size. No pre-trade negotiation is required, allowing this model to scale easily with customer growth. It generates substantial revenue without requiring balance-sheet deployment.

Account fees, custody fees, and infrastructure fees

These fees provide predictable, recurring revenue streams that are partially decoupled from transaction volume.

Business account maintenance fees typically range from €50 to €500 per month, depending on:

Custody fees generate revenue either as a percentage of assets held or as fixed service fees. These services generally do not require significant balance-sheet usage but can become sizable fee-generating operations when scaled organically.

Infrastructure fees cover access to payment rails, banking APIs, reporting systems, and white-label services. These recurring fees provide revenue stability during periods of lower transaction activity and reward the long-term banking relationship rather than customer activity alone.

Crypto neobanks commonly make monetisation mistakes that undermine profitability and long-term viability, particularly when pricing, revenue concentration, or product sequencing are misaligned with regulatory and operational realities.

Underpricing compliance-heavy customers

This leads to zero or negative profitability when neobanks underestimate the real cost of monitoring and reporting on customer activity.

Many neobanks go to market with aggressive pricing to achieve quick growth and customer acquisition. Transactions are priced in line with traditional banks, based on the assumption that crypto-related accounts can be serviced at similar cost levels. This assumption is flawed.

Crypto-based accounts require substantially heavier compliance and reporting resources, often 5–10× more than traditional accounts, including:

These activities consume significant personnel time per case and require substantial technology investment. Generic pricing models fail to account for this cost structure and are not designed to recoup it.

When unit economics turn negative, neobanks face a difficult choice: raise prices and lose customers, or continue operating at a loss in the hope that scale will eventually compensate.

Overreliance on interchange or a single source of monetisation

This creates catastrophic vulnerability when regulations, market conditions, or competitive dynamics change.

Neobanks that build their model primarily around card interchange revenues place their existence at risk. Interchange rates can be cut dramatically—sometimes by up to 90%—in response to compliance or regulatory imperatives.

Similarly, dependence on FX spreads for FX-based revenues exposes the business to customer concentration risk. Losing even a small number of high-volume customers can materially damage the entire operation.

A durable monetisation strategy requires multiple revenue streams across different activities, including:

Launching yield- or lending-based products too early

This exposes nascent neobanks to dangerous levels of credit and regulatory risk before they have developed the necessary expertise.

Lending products introduce volatility risk, rapid market condition changes, counterparty risk, and complex collateral management requirements that are fairly unique to crypto lending. Most early-stage neobanks do not yet possess the specialised knowledge or infrastructure required to manage these risks safely.

Offering deposit interest also subjects neobanks to an operationally intensive regulatory framework under banking law. At early stages, they are typically neither authorised nor equipped with suitably permissioned infrastructure to support such products.

Successful crypto neobanks remain focused on payment processing and account servicing for the first two to three years. They build monetisation around fee-based models before considering the introduction of yield-based products.

Choosing between an EMI license, a full banking license, or MiCA authorisation is a foundational decision for crypto neobanks, as each regulatory path determines speed to market, permitted activities, and long-term strategic flexibility.

Why Most Crypto Neobanks Start With an EMI License

Speed to market is the primary reason most crypto neobanks begin with an EMI license. An EMI license typically takes 6–18 months to obtain, while a full banking license can take 2–5 years.

EMI licensing also requires:

This timeframe is usually sufficient to prove or validate market demand for the neobank’s offering and to demonstrate operational competence using real-life transaction data rather than projections.

EMI licenses allow neobanks to issue electronic money, process payments, and provide account servicing across all EU member states through “passporting” notifications rather than requiring a separate license in each jurisdiction. This has enormous practical value for crypto businesses that often operate across multiple countries.

The trade-offs are equally clear. EMI-licensed institutions:

Despite these limitations, the speed-to-market advantage makes EMI licensing the preferred starting point for most crypto neobanks.

Where MiCA Fits Into Crypto Neobank Strategy

MiCA licenses authorise a narrow and specific set of activities related to crypto assets, including:

These are services for which neither a banking license nor an EMI license provides authorisation.

However, MiCA does not authorise activities commonly associated with banking. It cannot be used to execute euro-based payment transactions, process fiat payments, or maintain euro-denominated accounts. Authorisation under MiCA applies only to transactions specific to crypto assets and does not cover the payment flows required to maintain cash flow, pay employees, or manage company treasury operations.

As a result, MiCA does not replace the need for an EMI or banking license. Crypto neobank operations still depend on traditional fiat banking infrastructure, regardless of a business’s focus on crypto liquidity management.

MiCA should therefore be viewed as complementary. It encourages crypto neobanks to retain EMI or banking permissions for standard banking relationships while also obtaining MiCA authorisation to legally provide crypto-asset-specific services.

Scaling a crypto neobank from an EMI framework to a full banking license depends on clear signals of suitability, sustained profitability, and regulatory credibility.

Signals of suitability for scaling to a banking license

Key indicators include sustained profitability of more than €5 million per year, clear demand for banking-type products such as lending and deposits, and an established compliance track record.

Once a neobank demonstrates positive unit economics for more than two to three years, supported by multiple revenue sources and operational maturity, the economic case for applying for a banking license becomes credible. Demand from users for products not typically offered under an EMI framework—such as credit products, deposits, and sophisticated treasury management—signals constraints in the existing license.

Regulatory perception is decisive. Signals that regulators are likely to view the neobank favourably include:

Absent these conditions, approval is unlikely.

Capital and governance implications of a banking license

A banking license requires €5–15 million in initial capital, depending on jurisdiction. This capital is permanently invested and cannot be freely deployed in operations.

Governance standards are significantly higher and typically include:

Application costs range from €500,000 to €2 million in legal and consulting fees and require suitable supporting infrastructure. Core systems must meet stringent security, availability, and disaster recovery standards. These requirements are generally feasible only for neobanks with strong venture capital backing or high levels of profitability.

Reasons for avoiding a banking license

For many crypto neobanks, the EMI framework is sufficient for their intended activities. License requirements may be unrealistic in scale, or regulators may be inclined toward unfavourable decisions due to crypto’s unique risk profile.

Neobanks focused purely on payment processing, FX operations, and account management—with no ambition to offer lending—can operate effectively under an EMI license without the compliance burden or capital lock-up of a banking license.

For others, a strong crypto focus may itself be a disqualifying factor, as regulators associate it with systemic risk and money laundering concerns. Rather than pursuing low-probability applications, these neobanks focus on optimising EMI operations, maximising payment and FX revenue, and building businesses of sufficient value to attract acquisition interest from incumbent banks.

Clarity of the go-to-market strategy and a focused niche is the main requirement investors look for in crypto neobank business models. Investors need to assess whether the neobank can acquire customers at low cost and defend its business model over time.

They expect clear answers to questions such as:

A neobank targeting crypto exchanges with no interest in lending products and a clear value proposition is far more attractive than one that claims to serve all crypto businesses without focus. The go-to-market strategy must demonstrate the founder’s intimate knowledge of the niche, existing relationships that could convert into customers, and a credible hypothesis for why customers would switch providers.

A realistic licensing roadmap and evidence of regulatory readiness are equally essential. Investors need confidence that the business model can operate legally and unlock multiple markets rather than leading to regulatory dead ends.

They typically look for:

The licensing plan should clearly outline which jurisdictions the neobank will target, in what order, and whether the structure allows cross-border operations or sequential expansion. Investors also expect founding teams to understand the regulatory framework in depth and to have hired a credible chief compliance officer, often someone with prior experience at a regulator or an incumbent bank.

Durability of revenue and cost structure is critical in weeding out unviable business models. Investors assess whether revenue streams can survive crypto market downturns. Payment processing fees and subscription-based account fees are viewed as resilient, unlike revenues dependent on trading activity. This perspective explains why investors focus heavily on revenue quality during down markets, when trading fees may collapse.

The customer base must also demonstrate sufficient diversification, with no single customer contributing more than 10% of total revenue. Unit economics must be attractive at a granular level, showing positive gross margins for each customer once steady-state operations are reached.

The cost structure must support incremental operating leverage, meaning each additional customer adds value beyond the cost of serving them. Common investor rules of thumb include:

Leading crypto neobanks for businesses consistently succeed by adopting clear go-to-market (GTM) patterns built around vertical positioning rather than horizontal expansion across many product lines. Instead of trying to serve all crypto needs, successful players are explicit about who they serve—such as “banking for crypto exchanges” or “financial infrastructure for blockchain companies.”

They adopt a niche-first approach focused on deeply understanding and solving specific customer problems. Their positioning emphasises being a long-term partner rather than a vendor offering purely transactional banking services. These neobanks are also realistic about geographic scope: they do not claim global reach from day one and instead position themselves as specialists rather than generalists attempting to attract clients across unrelated verticals.

Successful neobanks clearly communicate their crypto friendliness to potential customers through multiple channels:

Crypto friendliness is also reinforced through product features designed for crypto-native use cases, including:

Lessons for founders to apply early rather than later include maintaining extreme niche focus even at small scale, investing early in compliance frameworks and expertise, and building strong personal relationships with early customers who later become referral sources.

Winning GTM patterns among the most successful crypto neobanks involve starting very small—typically with 50–100 clients—and focusing on a narrowly defined customer base, such as only exchanges, only NFT marketplaces, or only DeFi protocols. These neobanks prioritise strong relationships with initial customers while achieving product–market fit before expanding into new customer segments or use cases. Expansion is most effective when existing customers can act as references.

Founders are also disciplined about achieving profitability with this small customer base, using pricing that reflects real costs rather than relying on scale assumptions or early investment to subsidise losses. Only after demonstrating sustainable unit economics does raising capital for scalability become the priority.