OCC Expands Bank Authority for Crypto Custody and Trade Execution
The OCC confirmed that national banks and federal savings associations may execute customer-directed purchases and sales of crypto assets held in custody and may outsource permissible custody and execution services.
On May 7, 2025, the Office of the Comptroller of the Currency issued Interpretive Letter 1184, clarifying how national banks and federal savings associations could provide crypto-asset custody and execution services. The agency confirmed that banks may buy and sell assets held in custody at a customer’s direction and may use third parties for permissible crypto activities, including custody and trade execution, subject to appropriate risk management.
The letter built on earlier OCC guidance recognizing crypto custody as a modern form of traditional bank custody. Its practical importance was that a regulated bank did not need to treat the execution of a customer’s Bitcoin transaction as something categorically outside ordinary custodial banking powers. Banks could also rely on specialized sub-custodians rather than building every technical capability themselves.
For Bitcoin, the change lowered an institutional barrier between traditional banking and digital-asset infrastructure. It did not compel banks to offer Bitcoin services, but it clarified the legal pathway for banks that wanted to combine custody, transaction execution, and third-party technical providers within the federal banking system.