The Office of the Comptroller of the Currency (OCC) has issued new guidance outlining the conditions under which national banks and federal savings associations can engage in crypto-asset custody and execution services.
Released as Interpretive Letter 1184, the guidance confirms that these institutions may buy and sell crypto assets held in custody at a customer’s direction. Additionally, banks are permitted to outsource these services to third-party providers, as long as they follow sound risk management practices.
This clarification builds on previous OCC guidance, including Interpretive Letters 1170 and 1183, which first outlined the legal framework for banks engaging in digital asset activities. The new letter reinforces the idea that while banks may leverage third-party providers for crypto services such as custody and trade execution, they remain responsible for ensuring those arrangements meet regulatory expectations.
As with all banking operations, the OCC emphasized that crypto-related services must be conducted in a safe, sound, and legally compliant manner. This includes using qualified sub-custodians and implementing robust oversight of outsourced functions. The guidance offers banks a clearer path to participating in the growing crypto market while maintaining regulatory discipline and protecting customer interests.