OCC Confirms Banks Permitted To Pay Gas Fees

On November 18, 2025, the Office of the Comptroller of the Currency (OCC) issued Interpretive Letter 1186 (the "Letter"), which confirmed that national banks may: (1) "pay network fees on blockchain networks ("gas fees") to facilitate otherwise permissible activities"; (2) hold crypto-assets on their balance sheets "necessary to pay gas fees for which the bank anticipates a reasonably foreseeable need"; and (3) hold crypto-assets "necessary for testing otherwise permissible crypto-asset-related platforms . . . ."¹

Permissible Activities

The OCC cited a number of previous interpretive letters confirming crypto-asset activities permissible for national banks, including:

• Interpretive Letter 1170, affirming that banks may provide crypto-asset custody services;