The landscape of crypto-banking in the United States is undergoing a significant transformation as the Office of the Comptroller of the Currency (OCC) has issued new guidance permitting national banks to act as intermediaries for cryptocurrency transactions. This important update, detailed in Interpretive Letter 1188 released on December 9, 2025, represents a crucial advancement in the integration of digital assets within the country”s regulated financial framework.
The OCC”s recent directive allows national banks to engage in what are termed “riskless principal” transactions involving cryptocurrency. In this model, a bank temporarily acquires a digital asset from one client and immediately sells it to another, ensuring a fully offsetting transaction. Because banks do not hold inventory or face prolonged market exposure, such activities are deemed low-risk and align with established brokerage practices recognized in traditional finance.
The letter makes it clear that these transactions are effectively equivalent to long-standing practices in securities intermediation. This reinforces the OCC”s perspective that financial operations should be regulated according to inherent risk rather than the technology employed, continuing the agency”s technology-neutral stance that acknowledges cryptocurrency as a modern evolution of traditional financial services.
Regulatory Compliance and Risk Management
While banks are now authorized to facilitate crypto trades, they must adhere to stringent supervisory requirements. The OCC has stressed that institutions engaging in crypto intermediation must establish:
- Robust risk management controls
- Comprehensive customer protections
- Strong compliance systems
- Safe and sound operational frameworks
These banks will be subject to the OCC”s standard supervisory processes, ensuring that their activities surrounding digital assets align with the safety expectations that govern the broader banking sector.
Shifting Regulatory Landscape
This new guidance comes at a pivotal time for American financial regulators. In 2025, agencies such as the OCC, the Federal Reserve, and the Federal Deposit Insurance Corporation (FDIC) have been revising earlier restrictive positions that discouraged banks from providing digital asset services. The prevailing message among regulators is becoming increasingly clear: digital asset activities can function within the bounds of regulated banking when performed responsibly.
This shift in policy symbolizes a concerted effort to modernize banking practices and meet the growing institutional demand for compliant infrastructure in the cryptocurrency space. By enabling banks to engage in crypto transactions without taking on balance-sheet risk, regulators are laying the groundwork for a more integrated relationship between traditional finance and the burgeoning digital asset economy.
