OCC Confirms National Banks Can Intermediate Crypto Trades as Riskless Principal
OCC Interpretive Letter 1188 confirmed that national banks may execute crypto-asset transactions as riskless principal, acting between customers while simultaneously offsetting the position instead of holding crypto inventory. The decision expanded the ways federally chartered banks could intermediate Bitcoin and other crypto trades.
On December 9, 2025, the Office of the Comptroller of the Currency published Interpretive Letter 1188 confirming that national banks may engage in riskless-principal transactions involving crypto-assets. In this structure, a bank acts as principal to a customer's trade while simultaneously executing an offsetting transaction, leaving the bank without a continuing inventory position in the asset.
The model is familiar in traditional markets. It allows a bank to intermediate transactions while managing principal risk in a way economically similar to brokerage. Applying that authority to crypto-assets mattered because it gave federally chartered banks a clearer legal basis for facilitating customer Bitcoin transactions without requiring them to maintain a speculative Bitcoin position on their own balance sheet.
The OCC did not declare crypto trading risk-free or exempt banks from ordinary supervisory obligations. It expressly required the activity to be conducted safely, soundly, and in compliance with applicable law. The importance of the letter was therefore institutional permission rather than deregulation: crypto intermediation could fit within the recognized business of banking when structured through an established riskless-principal model.
For Bitcoin, the decision further narrowed the divide between specialist digital-asset trading firms and conventional banks. Earlier stages of institutional adoption had focused heavily on custody, ETFs, and derivatives. Interpretive Letter 1188 addressed transaction execution itself, clarifying how a national bank could stand between a Bitcoin buyer or seller and an offsetting market transaction within the federal banking framework.