VOL. I · OCT. 17, 2026 ● NO. 07 ● SEX WORK, SPEECH & THE BODY
The White Rose
“We will not be silent.”
Wir schweigen nicht — after Sophie Scholl
The desk for sex-worker rights and adult-content law — age-verification mandates, platform bans, FOSTA-SESTA, and the fight over who may speak about sex.
De-banking
Federal Regulators Move to Curb the De-Banking of Adult Creators
A 2025 executive order and a 2026 OCC-FDIC rule strip "reputation risk" from bank supervision, a category long used to cut off adult-industry accounts.

Bank branch signage. New federal rules target the 'reputation risk' rationale behind adult-industry account closures. — AI-generated illustration
Federal banking regulators are dismantling the supervisory tool most often blamed for cutting adult-content creators off from the financial system. In April 2026 the Office of the Comptroller of the Currency and the Federal Deposit Insurance Corporation adopted a joint rule barring examiners from relying on "reputation risk," implementing a August 2025 executive order that ordered an end to politicized de-banking of lawful businesses.
For years, sex workers and adult creators have described losing bank accounts, payment rails and card-network access without explanation, a pattern academics and advocates label the financial de-platforming of sex workers. Institutions frequently cited reputational risk, an amorphous category that let supervisors discourage entire lawful sectors without pointing to any safety-and-soundness problem.
Executive Order "Guaranteeing Fair Banking for All Americans," signed August 7, 2025, directed regulators to remove reputation risk from their examination frameworks and to scrutinize institutions that deny service based on lawful but disfavored activity. The OCC separately reviewed the nine largest national banks over 2020-2023 and concluded that sector-wide restrictions had been applied in place of individualized risk assessment.
The resulting OCC-FDIC final rule prohibits the agencies from directing banks to close accounts, or taking supervisory action, on the basis of a customer's political, social or religious views or a lawful line of business. The Comptroller said reputation risk had "too often" served as a pretext for decisions unrelated to safety and soundness. Adult-industry lawyers say the change gives de-banked creators firmer ground to contest account closures, though the rule does not compel any bank to take a specific customer and card-network policies remain a separate hurdle.
9
Largest banks reviewed by the OCC
2020-2023
Review period
as a pretext for decisions that have nothing to do with safety and soundness
— Comptroller of the Currency
Video caption
How the case moved
2025-08-07
Executive Order 'Guaranteeing Fair Banking for All Americans' signed
2026-04
OCC and FDIC adopt joint final rule removing reputation risk from supervision
✓ Fact check
Claim
“The new federal rule forces banks to open accounts for adult creators.”
Reality
The rule bars regulators from using reputation risk to pressure banks; it does not compel any institution to serve a particular customer, and card-network policies are unaffected.
§
Legal References
Bluebook citation · cases, statutes & the record
Primary legal authority cited in this report. Links go to the public record where one exists.
[1]
Executive Order, Guaranteeing Fair Banking for All Americans, Exec. Order (Aug. 7, 2025); OCC-FDIC joint final rule on reputation risk (2026) ¶ source
Executive Branch / OCC / FDIC 2026
¶
Academic References
ABA / law-review style · secondary scholarship
Secondary scholarship that informs the analysis.
[1]
Reference text
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