Clarification of Bank Authority Regarding Crypto-Asset Custody Services: Office of the Comptroller of the Currency (OCC) // LETTER #1184

Whoa, even the office of the comptroller of the currency (USA GOV), calls it fiat currency?

Banks:

1. Cryptocurrency Fiat currency exchange
2. Transaction settlement
3. trade execution **-> big deal! You can use bank to buy bitcoin

Banks may provide and outsource cryptocurrency custody and execution services on behalf of customers, buy and sell digital assets held in custody at the direction of the customer, odd source being permissible crypto acid activities to third parties (probably Coinbase), with proper risk management.

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Interpretive Letter #1184

Date: May 7, 2025

Subject: Clarification of Bank Authority Regarding Crypto-Asset Custody Services

From: Office of the Comptroller of the Currency (OCC)

Signed by: Rodney E. Hood, Acting Comptroller of the Currency

Dear [                  ],

This letter responds to your request asking the OCC to confirm that national banks and federal savings associations (“banks”) may:

• Provide and outsource cryptocurrency custody and execution services on behalf of customers,
• Buy and sell assets held in custody at the direction of the customer, and
• Outsource bank-permissible crypto-asset activities to third parties, with proper risk management.

Background

• Interpretive Letter 1170: Confirmed banks may provide crypto-asset custody services in fiduciary or non-fiduciary capacity.
• Interpretive Letter 1183: Recently reaffirmed 1170’s conclusions.

Custody of crypto-assets is considered a modern extension of traditional bank custody services.

Key Points

• Banks may provide services such as:
  
  • Cryptocurrency/fiat currency exchange,
  • Transaction settlement,
  • Trade execution,
  • Recordkeeping,
  • Valuation,
  • Tax services,
  • Reporting.
• Banks may engage sub-custodians for crypto-assets, provided:
  
  • Sub-custodians have proper internal controls,
  • Banks ensure risk management and compliance with laws.
• Execution of customer-directed trades and use of third-party providers are permissible.
• Regulatory compliance:
  
  • If acting in a fiduciary capacity:
    
    • National banks: 12 C.F.R. Part 9
    • Federal savings associations: 12 C.F.R. Part 150
  • Must maintain safe and sound practices.

Conclusion

Banks may engage in customer-directed crypto custody and execution services, including outsourcing to qualified third parties, in compliance with applicable laws and fiduciary regulations.

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