July 25, 2025

Vol. XLII, No. 8

OCC Streamlines Process for Cryptocurrency (National Banks and Federal Savings Associations)

I. Introduction
The Office of the Comptroller of the Currency (OCC) has issued guidance on national bank and federal savings association participation in certain cryptocurrency activities (Interpretive Letter 1183). The guidance is the latest step by federal regulators to remove impediments to banks and financial services institutions to engage in crypto-related businesses.

In Interpretive Letter 1183, the OCC reaffirms the permissibility of certain cryptocurrency-related activities for OCC-regulated institutions and rescinds requirements for OCC-supervised institutions to receive supervisory nonobjection and demonstrate that they have adequate controls in place before they can engage in these cryptocurrency activities.

II. Background
The OCC previously issued three Interpretive Letters in 2020 and early 2021 addressing whether it is permissible for national banks and federal savings associations to engage in certain cryptocurrency, distributed ledger, and stablecoin activities. The Interpretive Letters are:

• OCC Interpretive Letter 1170, addressing whether banks may provide cryptocurrency custody services;
• OCC Interpretive Letter 1172, addressing whether banks may hold dollar deposits serving as reserves backing stablecoin in certain circumstances; and
• OCC Interpretive Letter 1174, addressing whether (1) banks may act as nodes on an independent node verification network (i.e., distributed ledger) to verify customer payments and (2) banks may engage in certain stablecoin activities to facilitate payment transactions on a distributed ledger.

The OCC subsequently issued Interpretive Letter 1179 clarifying that the activities addressed in the interpretive letters above are legally permissible for national banks and federal savings associations to engage in, provided they can demonstrate, to the satisfaction of its supervisory office, that they have controls in place to conduct the activity in a safe and sound manner.

III. OCC Reassessment
Interpretive Letter 1183 rescinds the 2021 Letter (Interpretive Letter 1179) imposing the nonobjection and affirmative risk management obligations.

Interpretive Letter 1183 confirms that crypto-asset custody, certain stablecoin activities, and participation in independent node verification networks are permissible for OCC-supervised institutions, but rescinds the 2021 Letter (Interpretive Letter 1179) imposing the nonobjection and affirmative risk management obligations.

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The foregoing Compliance Update is for informational purposes only and does not constitute legal advice. As a reminder, the NBA general counsel is the attorney for the Nebraska Bankers Association, not its member banks. The general counsel is available to assist members with finding resources to help answer their questions. However, for specific legal advice about specific situations, members must consult and retain their own attorney.