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ARTICLE · 28 JULY 2020

OCC Allows National Banks To Provide Digital Asset Custody Services

Hogan Lovells Cadwalader
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The OCC confirmed that state and national banks and thrifts may provide cryptocurrency and digital asset custody services, including by holding "unique cryptographic keys."

United StatesTechnology

The OCC confirmed that national banks and federal savings associations may provide cryptocurrency and digital asset custody services, including by holding "unique cryptographic keys."

In an interpretive letter, the OCC reaffirms that national banks may provide all permissible banking services to cryptocurrency businesses "so long as they effectively manage the risks and comply with applicable law[s]," including anti-money laundering requirements.

The OCC emphasized that the proposed custodial services represented traditional banking activity being applied to a new type of asset. Further, the OCC stated that it recognized the need for banks to leverage new technology to provide traditional services to their customers so that "banks can continue to fulfill the financial intermediation function they have historically played in providing payment, loan and deposit services."

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