On May 7, 2025, the OCC issued Interpretive Letter 1184 to clarify a bank’s authority regarding crypto-asset custody services. The letter was issued in response to a request for the agency to confirm that national banks and federal savings associations may provide and outsource cryptocurrency custody and execution services on behalf of customers.
An undisclosed entity requested the OCC to confirm that banks may buy and sell customer assets upon request and hire outside companies for crypto-asset activities, like custody and execution services, subject to appropriate third-party risk management practices. Citing Interpretive Letter 1170, which was re-affirmed by the OCC by issuing Interpretive Letter 1183 in early March, the OCC clarified that a bank may buy and sell assets held in custody on a customer’s behalf at the direction of the customer and in a manner consistent with the customer agreement and applicable law. The OCC added that a bank may use a sub-custodian to provide custody services subject to appropriate third-party risk management practices. The OCC emphasized that banks must conduct crypto-asset custody activities, including through a sub-custodian, in a safe and compliant manner with applicable laws.
Read Interpretive Letter 1184 here.