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ARTICLE · 17 DECEMBER 2025

OCC Confirms Riskless Principal Transactions In Crypto Assets By Banks Are Permissible

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The Office of the Comptroller of the Currency ("OCC") confirmed national banks may engage in riskless principal crypto-asset transactions.

United StatesTechnology
Nathan Brownback
Nathan Brownback
Michael Dawson
Michael Dawson
Abradat Kamalpour
Abradat Kamalpour
Nicholas Podsiadly
Nicholas Podsiadly
Mark W. Rasmussen
Mark W. Rasmussen
Michael Rust
Michael Rust
Benjamin M. Wiest (Ben)
Benjamin M. Wiest (Ben)
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The Office of the Comptroller of the Currency ("OCC") confirmed national banks may engage in riskless principal crypto-asset transactions.

On December 9, 2025, the OCC issued Interpretive Letter #1188 to confirm that national banks may engage in riskless principal crypto-asset transactions, including transactions in assets that are not securities. Riskless principal transactions occur when an intermediary purchases an asset from one counterparty for immediate resale to a second counterparty. Banks are generally permitted to engage in such transactions and the OCC does not view involvement of crypto assets in the transactions as preclusive to banks' engagement.

The OCC held that riskless principal crypto-asset transactions are permissible as a "part of the business of banking," and weighed the four factors set forth in 12 C.F.R. § 7.1000(c)(1):

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