On November 18, 2025, the OCC issued Interpretive Letter 1186, confirming that national banks may hold certain crypto-assets as principal when necessary to pay blockchain network fees associated with otherwise permissible activities.
Under the letter, banks may maintain on-balance-sheet amounts of crypto-assets, such as those used for “gas fees”, when there is a reasonably foreseeable operational need. The OCC also clarified that banks may hold limited crypto-assets as principal for testing permissible crypto-asset platforms, whether developed internally or obtained from third parties.
As with any activity, banks must ensure that crypto-asset holdings and related operations are conducted in a safe and sound manner and in full compliance with applicable laws and supervisory expectations.
Read the OCC’s press release here.
Interpretive Letter 1186 can be found here.