OCC’s Recent Guidance on Cryptocurrency: A Step Toward Mainstream Banking Integration

In the evolving landscape of financial regulation, the Office of the Comptroller of the Currency (OCC) has issued significant guidance on cryptocurrency activities for national banks and federal savings associations. These announcements, released during the week of December 2–9, 2025, reflect a deliberate shift toward facilitating innovation while prioritizing risk management and compliance. This article provides a comprehensive summary of the key developments, offering insights into their implications for the banking sector and the broader digital asset ecosystem.

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Holding Crypto-Assets for Network Fees: Interpretive Letter 1186 (December 8, 2025)

The OCC’s Interpretive Letter 1186 addresses the permissibility of banks holding limited quantities of crypto-assets to cover transaction costs, commonly referred to as “gas fees,” on blockchain networks. This guidance permits institutions to maintain such assets as principal when they support permissible activities, such as digital asset custody or stablecoin operations. Additionally, banks may hold small amounts for internal testing or evaluation of third-party crypto platforms.

This ruling is grounded in the principle that these holdings are incidental to core banking functions and do not inherently pose undue risks if conducted under robust safety and soundness protocols. Notably, the OCC does not require prior supervisory non-objection for these activities, provided banks adhere to established risk management frameworks. This development builds upon earlier 2025 policy adjustments, including the rescission of more restrictive interpretive letters, signaling a regulatory environment increasingly supportive of crypto infrastructure.

For educational context, “gas fees” represent the computational costs required to process transactions on networks like Ethereum. By allowing banks to hold crypto-assets for this purpose, the OCC enables more efficient participation in blockchain-based services, potentially reducing operational barriers for institutional players.

Riskless Principal Transactions in Crypto-Assets: Interpretive Letter 1188 (December 9, 2025)

Complementing the prior guidance, Interpretive Letter 1188 authorizes national banks to engage in “riskless principal” transactions involving crypto-assets. In these arrangements, a bank acts as an intermediary by purchasing an asset from one customer and simultaneously selling it to another in fully offsetting trades, thereby avoiding market risk exposure. The OCC classifies this as part of the “business of banking,” analogous to traditional securities transactions.

The letter acknowledges potential risks, such as settlement delays and counterparty credit issues, but concludes that blockchain technology does not fundamentally alter the activity’s permissibility. Institutions must implement appropriate controls, including real-time transaction matching, and will be subject to ongoing supervisory examinations. This guidance responds to inquiries from entities seeking crypto-focused bank charters, aligning with the OCC’s broader efforts to foster innovation.

From an educational perspective, riskless principal transactions minimize a bank’s exposure to price volatility, making them a low-risk entry point for crypto facilitation. This could enhance liquidity in digital asset markets by leveraging banks’ established trust and infrastructure.

Broader Context: Remarks on Crypto Charters and Innovation

In a related speech on December 8, 2025, tied to News Release 2025–120 on de novo bank chartering, OCC Comptroller Jonathan Gould addressed criticisms from traditional banks regarding crypto firms pursuing federal charters. He emphasized that historical innovations — from telegraphs to blockchains — should not be impeded, highlighting 14 new charter applications in 2025, including those from prominent crypto entities like Erebor and Anchorage.

While not a standalone crypto directive, these remarks underscore the OCC’s commitment to a balanced regulatory approach. By defending the chartering process, Gould reinforces the agency’s view that competition and technological advancement benefit the financial system, provided risks are mitigated.

Implications for the Financial Sector

These announcements collectively indicate a pivotal evolution in U.S. banking regulation, moving away from cautionary stances toward enabling controlled crypto integration. For banks, this means expanded opportunities in custody, payments, and trading services, potentially attracting institutional capital and enhancing competitiveness. However, the emphasis on risk management ensures that activities remain aligned with prudential standards, protecting depositors and the financial system.

Educators and professionals in finance should note that this guidance does not endorse unrestricted crypto engagement; rather, it promotes measured adoption. Stakeholders are encouraged to review the full interpretive letters on the OCC’s website for detailed compliance requirements.

In conclusion, the OCC’s 2025 crypto guidance represents a forward-thinking framework that bridges traditional banking with digital innovation. As the sector adapts, ongoing dialogue between regulators and industry participants will be essential to realizing these benefits while safeguarding stability.

Author: Trent V. Bolar, Esq. (LinkedIn Profile)

Disclaimer: All content in this article is intended for general information only and should not be construed as legal or financial advice. Consult a qualified attorney for personalized guidance on legal matters. Information in this article may not constitute the most up-to-date legal or other information. The content in this article is provided “as is,” and no representations are made that the content is error-free. Use of, and access to, this article or any of the links or resources contained within does not create an attorney-client relationship between the reader, user, or browser and the author. All trademarks, logos, and service marks used in this article are the property of their respective owners. The use of such trademarks does not imply any affiliation with or endorsement of this article.

© 2025 Trent V. Bolar, Esq. | All rights reserved.

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