OCC Charters and Guidance Accelerate Regulated Crypto Banking

As 2025 draws to a close, U.S. banking regulators have delivered a series of clarifications and approvals that significantly ease national banks’ participation in cryptocurrency activities, signaling a broader shift toward mainstream adoption of digital assets under federal supervision.

The U.S. Office of the Comptroller of the Currency (OCC) has led this momentum with multiple interpretive letters throughout the year, treating digital asset functions as part of standard banking authority.

Regulatory Framework and Bank Participation

In its latest move, Interpretive Letter 1188, the OCC confirmed that national banks may engage in “riskless principal” transactions involving any crypto asset, regardless of its classification as a security

This enables banks to serve as intermediaries by pairing customer buy and sell orders without taking on market risk or holding the crypto themselves, effectively operating like regulated brokers.

The guidance emphasizes that such activities must be conducted in a safe and sound manner, adhering to existing risk management standards for counterparty credit and settlement risks

The move marks a significant step toward integrating digital assets into traditional banking services.

Just days after, the OCC announced conditional approvals for national trust bank charters to five prominent crypto firms: Circle (through First National Digital Currency Bank), Ripple (Ripple National Trust Bank), and conversions for BitGo, Fidelity Digital Assets, and Paxos

These special-purpose charters focus on custody and fiduciary services for digital assets, without deposit-taking or FDIC insurance.

Broader Regulatory Momentum in Digital Assets

The December announcements are part of a series of pro-crypto actions by the OCC in 2025, reflecting a shift toward clearer regulatory pathways for banks in the digital asset space.

Earlier in the year, the agency reaffirmed the permissibility of crypto-asset custody, stablecoin-related activities, and participation in distributed ledger networks

In November, another letter allowed banks to hold limited amounts of crypto-assets as principal to cover blockchain network fees or for platform testing.

Traditional banks have raised concerns over competitive fairness and risk oversight, warning that trust charters could result in lighter regulation for crypto-focused entities.

Industry experts see this as a sign that institutional adoption is picking up, with banks now able to provide smooth crypto transfer and settlement services to clients while keeping risks under a regulated framework.

Why This Matters

This move lets U.S. banks safely expand crypto services under federal oversight, supporting wider adoption and more stable, regulated digital markets.

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People Also Ask:

What are “riskless principal” transactions in crypto? These are transactions where a bank acts as an intermediary, buying a crypto asset from one customer and immediately selling it to another in offsetting trades. The bank does not hold the asset or take market price risk, functioning similarly to a regulated broker.

Do these new crypto trust banks accept deposits or have FDIC insurance? No. These are limited-purpose national trust banks that do not take deposits and are not covered by FDIC insurance, distinguishing them from traditional commercial banks.

Why is the OCC’s 2025 guidance significant for crypto adoption? It removes prior regulatory uncertainty, treats crypto activities as standard banking authority when properly risk-managed, and enables banks to compete with unregulated platforms while offering safer, supervised services to institutional and retail clients.

What risks do banks still need to manage under this new guidance? Banks must adhere to existing standards for counterparty credit risk, settlement risk, operational resilience, anti-money laundering (AML), and consumer protection. They cannot assume market price risk in riskless principal trades and must ensure activities are conducted safely and soundly.

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