This includes trading digital assets held in custody and outsourcing certain functions to third-party providers. In a letter dated 7 May 2025, the OCC stated that national banks and federal savings associations can buy and sell cryptocurrencies as directed by customers, provided the assets are already held in custody. The regulator also confirmed that institutions may delegate crypto-related services such as custody and execution to external firms, so long as such arrangements comply with existing banking laws and risk management standards.
According to a video statement released the same day, OCC officials noted that banks may also offer ancillary custody services, such as maintaining records, handling tax reporting, and providing sub-custodian arrangements. However, all third-party engagements must be subject to the OCC’s established oversight frameworks for managing risk.
The confirmation follows an earlier policy shift from the OCC in March, when it authorised banks to participate in select digital asset activities. These include custody of crypto-assets, engagement with certain stablecoin-related functions, and participation in distributed ledger networks.
The OCC’s recent statements have been interpreted by some in the digital asset sector as indicative of a broader move towards integrating cryptocurrencies into traditional financial systems. Representatives from blockchain infrastructure provider StarkWare remarked that the letters reflect a change in tone from the OCC and may reduce regulatory uncertainty for banks considering involvement in crypto services. They suggested that explicit approval for outsourcing bank-permissible crypto activities could benefit regulated service providers operating within the crypto space.
A representative from crypto exchange Coinbase also commented on the OCC’s approach, describing it as aligned with a commitment to supervisory standards and regulatory clarity. The OCC operates as an independent agency within the US Department of the Treasury, tasked with overseeing national banks and federal branches of foreign banking institutions.
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