OCC Confirms Banks May Provide Crypto Custody And Execution Services For Customers

On May 7, 2025, the Office of the Comptroller of the Currency (OCC) published Interpretive Letter 1184 (the Letter) which confirms that OCC-regulated national banks and federal savings associations may buy and sell custodied crypto assets at their customers' direction and may outsource crypto-asset activities that are otherwise permitted for banks, subject to appropriate risk management practices.¹

In the Letter, the OCC notes two prior interpretive letters: Interpretive Letter 1183, which removed a requirement for national banks and federal savings associations to receive supervisory non-objection before engaging in crypto-asset custody activities (and which we wrote about here), and Interpretive Letter 1170, which established that national banks may engage in crypto-asset custody activities, either as a fiduciary or non-fiduciary.² Interpretive Letter 1170 also stated that banks providing custody services may do so in several different manners consistent with