On May 7, the OCC issued Interpretive Letter 1184, reaffirming that national banks and federal savings associations may provide cryptocurrency custody and execution services, including through sub-custodians. The OCC confirmed that these activities are permissible under existing banking authority so long as banks comply with applicable law and engage in safe and sound practices.

The letter builds upon earlier OCC guidance, including Interpretive Letters 1170 and 1183. Specifically, the OCC clarified the following:

Putting It Into Practice: The OCC’s latest guidance offers banks further regulatory clarity in connection with crypto-related services (previously discussed here and here). Banks considering entry into the digital asset space should track these regulatory shifts closely and ensure their compliance, risk management, and third-party oversight frameworks are equipped to support crypto operations.

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