National Banks and Federal Savings Associations Are Permitted to Provide Custody and Trading Services for Digital Assets

The Office of the Comptroller of the Currency (OCC) has released guidance stating that national banks and federal savings associations are permitted to provide custody

The Office of the Comptroller of the Currency (OCC) has issued guidance confirming that national banks and federal savings associations can provide custody and trading services for digital assets, such as Bitcoin.

Interpretive Letter 1184 clarifies that banks are permitted to buy and sell digital assets on behalf of customers and may outsource related services—such as custody and execution—to third-party providers, subject to appropriate risk management oversight.

The guidance is part of the OCC’s broader regulatory efforts to clarify the scope of activities banks can undertake in relation to emerging financial technologies.

According to the letter, financial institutions may also provide related services, including recordkeeping, tax reporting, and compliance.

These services may be delegated to sub-custodians, provided that oversight requirements are met.

In a video statement, Acting Comptroller of the Currency Rodney Hood said, “this digitalization of financial services is not a trend. It is a transformation.”

OCC-regulated banks may buy and sell assets held in custody and are permitted to outsource bank-permissible crypto-asset activities, including custody and execution services.

Institutions providing crypto-asset custody services for their customers must comply with applicable risk management principles. These services may be delegated to sub-custodians, with institutions expected to maintain effective supervision over the sub-custodian in accordance with administrative capabilities.

According to the statement, financial institutions engaging in these activities are expected to implement the necessary risk controls and follow existing legal and supervisory expectations.

The guidance does not require banks to participate in Bitcoin or digital asset services, but it clarifies what is permissible under current law. Institutions may decide whether and how to engage in these activities based on their own business models, capabilities, and risk assessments.