New Strides In Crypto-Asset Regulation

On November 23, 2021, the Office of the Comptroller of the Currency (OCC) released Interpretive Letter 1179 (the " Letter"), which is the culmination of a review of prior Interpretive Letters on cryptocurrency and related activities. The Letter sets forth a process that requires a notice and non-objection before a national bank or federal savings association (collectively, "Banks") may engage in such activities.  That same day, the OCC, along with the Federal Reserve Board and Federal Deposit Insurance Corporation (FDIC) (collectively, the "Agencies"), released the Joint Statement on Crypto-Asset Policy Sprint Initiative and Next Steps (the " Statement"), which detailed the Agencies' policy sprint on crypto-assets and the work undertaken by the Agencies in conducting an analysis of crypto-asset issues. Taken together, and in the context of other recent government issuances, the Letter and the Statement represent an ongoing, and increasingly forceful, government