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ARTICLE · 24 JULY 2025

Federal Banking Regulators Issue Joint Guidance On Crypto-Asset Safekeeping

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On July 14, the OCC, Federal Reserve, and FDIC announced the release of a joint statement clarifying how existing laws and regulations apply to crypto-asset safekeeping...

United StatesTechnology
A.J. Dhaliwal
A.J. Dhaliwal
Mehul Madia
Mehul Madia
Maxwell Earp-Thomas
Maxwell Earp-Thomas
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On July 14, the OCC, Federal Reserve, and FDIC announced the release of a joint statement clarifying how existing laws and regulations apply to crypto-asset safekeeping services offered by banking organizations. The statement does not impose new supervisory expectations but reinforces how banking organizations must apply established fiduciary duties, risk management standards, and third-party oversight frameworks when holding crypto-assets on behalf of customers.

The guidance provides an overview of crypto-asset safekeeping standards, defining "safekeeping" as the service of holding a crypto-asset on a customer's behalf. Importantly, the guidance emphasizes that safekeeping involves maintaining exclusive control over the cryptographic keys required to transfer or manage digital assets. A banking organization is considered to have "control" for safekeeping purposes when it can demonstrate that no other party, including the customer, has access to information that

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