These letters effectively rendered the critical “non-objection” practice from the 2021 agreement obsolete. They also led to the OCC’s withdrawal from two interagency warnings about crypto-related risks in 2023.
The Office of the Comptroller of the Currency (OCC) has issued new guidance permitting national banks and federal savings associations to engage in cryptocurrency-related activities without prior regulatory approval.
Aligned with recent actions by the Federal Reserve, this policy change paves the way for national banks to provide crypto custody, facilitate trades at the direction of customers, and outsource digital asset services, all while adhering to established third-party risk management guidelines.
The OCC supported the policy shift with two vital letters – Interpretive Letter 1183, dated March 7, and Interpretive Letter 1184, dated May 7.
Letter 1184 expands on what activities national banks are permitted to pursue. It allows them to trade cryptocurrencies on customers’ behalf, buy and sell coins, and partner with sub-custodians to store digital assets, as long as they have robust risk management practices.
The OCC said the updates reflect the continuing evolution of the financial system. Acting Comptroller Rodney E. Hood emphasized that institutions that wish to conduct new activities in a bank should be in close, direct communication with the agency to ensure those activities stay safe and sound. He also said that the OCC wants banks to have adequate risk management in place for new services and those they have offered for some time.
That paves the way for traditional banks to lure customers away from services that were until recently the preserve of fintech companies and crypto-native platforms.
These policy updates align with the Federal Reserve’s April 24 decision to retract its pre-approval guidance for crypto activities, which had applied to state member banks.
The emergence of this new alliance between the OCC and the Fed shows that there is a coordinated effort by the federal regulators to bring banking services that bring cryptos into the mainstream.
The OCC said the U.S. banking system is now considered “well-positioned” to facilitate digital asset activity as long as operations are safe, sound, and fair.
But Sen. Cynthia Lummis, a well-known crypto backer, has vowed to continue supporting crypto until no obstacle is left. She and others advocate that more supportive language be used to allow innovation to proceed.
With the path now clear, national banks are preparing to launch crypto offerings, including custody services for digital assets and settlements through stablecoins and tokenized asset management.
The decision mirrors broader market changes and increasing customer demand for digital assets. An April 2025 Harris Poll showed that an estimated 55 million Americans—roughly 1 in 5—are partial owners of some form of cryptocurrency.
The migration to digital in financial services is no fad, Hood said, but a major sector evolution. He said the OCC regards digital finance as integral to the future of banking rather than a trend or fad.
The world’s Crypto market cap is now approximately $3.33 trillion. That shows the financial stakes for banks that stand to gain custody fees, transaction revenues, and long-term customer loyalty in a fast-growing industry.
Big banks are already in a position to take advantage of this opportunity. Some of them, such as JPMorgan Chase, BNY Mellon, and Citigroup, have indicated they are building new crypto service teams or enlarging their digital asset infrastructure.
However, while the doors of regulation open, there are challenges in implementing the ideal. Banks still need to construct the technology, train their staff, and construct risk compliance models commensurate with the particular risks of crypto, such as cybersecurity, asset volatility, custodial integrity, etc.
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