OCC Reframes Crypto as Standard Banking Activity

U.S. banking regulators are warming up to cryptocurrency in a way never seen before.

For much of the digital asset sector’s history, crypto companies have accused U.S. regulators of regulatory arbitrage by enforcement, while regulators accused the industry of racing ahead of basic risk controls. Banks, caught in the middle, largely stayed on the sidelines, experimenting quietly while waiting for a clearer signal.

The Office of the Comptroller of the Currency (OCC) has spent much of 2025 repeatedly flashing that clearer signal to banks, with the latest green light coming Tuesday (Dec. 9) with the news that banks can engage in permissible activities related to riskless principal transactions in crypto assets, aka brokering cryptocurrency assets for customers.

Over the course of the year, the OCC has issued no fewer than four crypto-specific interpretive letters, as well as additional crypto-adjacent letters, affirming the authority of national banks to engage in a widening set of digital asset activities. These include activities pertaining custody of cryptocurrency assets, participation in distributed ledger networks, settlement activities, and now brokering crypto assets on behalf of customers.

At the same time, Comptroller J. Gould on Monday (Dec. 8) publicly emphasized his desire to “invigorate the chartering of new banks,” a remark that lands squarely in the context of fintech, crypto-native institutions, and the long-dormant promise of special-purpose charters.

Taken together, these moves do not amount to a wholesale embrace of cryptocurrency. The OCC remains careful, conditional, and explicit about safety and soundness. But they do represent something more significant: a coherent point of view that cryptocurrency, while risky and uneven, is no longer categorically outside the perimeter of mainstream banking.

Read more: OCC Says Banks Can Hold Crypto, but Should They?

What This Means for Mainstream Finance

It is important to note that interpretive letters are not rulemakings. They do not create new law, nor do they bind other regulators. But within the OCC’s ecosystem, they matter. They clarify how the agency reads existing statutes and regulations, and they shape how examiners approach real-world activities.

PYMNTS reported in July that the confirmation of Jonathan Gould as comptroller of the currency signaled a relaxation of digital asset regulations, particularly for banks, and an easier path for some nonbanks and digital upstarts to obtain banking charters.

Gould has previously been chief legal officer at blockchain firm Bitfury and, before that, served as senior deputy comptroller and chief counsel at the OCC during the first Trump administration.

This year’s worth of OCC letters follow a consistent structure. Each begins by reaffirming that national banks may engage in activities that are part of, or incidental to, the business of banking, provided those activities are conducted in a safe and sound manner and comply with applicable laws. Crypto, the OCC essentially says, is not a category unto itself; it is a set of technologies and assets that can fall within existing banking authorities.

Earlier letters addressed custody of crypto assets, including holding private keys on behalf of customers. That alone marked a meaningful shift from the era when banks worried that custody implied endorsement or balance-sheet exposure. The OCC’s view was narrower: custody is a service, not a bet, and banks already hold valuable assets for customers every day.

See also: Building the Blockchain Blueprint: How Leading FIs Are Modernizing Money, Markets and Trust

Subsequent guidance extended that logic to participation in distributed ledger networks for payments and settlement, including the use of stablecoins to facilitate transactions. Again, the framing mattered. The OCC was not blessing any particular token or blockchain. It was stating that if a digital representation of value functions as a payment mechanism, banks can interact with it — subject to controls.

The most recent letter, authorizing banks to broker crypto assets for customers, completes the arc. Brokerage is not custody. It implies execution, market access, disclosures and customer-facing risk management. In effect, the OCC is acknowledging that crypto markets are no longer niche venues but trading environments that customers expect their financial institutions to help them navigate.

This insistence on normalization cuts both ways. For banks, it lowers the conceptual barrier to entry. Cryptocurrency is just another asset class, another infrastructure layer, another service offering. For crypto-native firms hoping for lighter treatment, it is a sobering message: access to the banking system comes with banking-grade obligations.

The next, and perhaps most pressing, question is what businesses will do in this fresh landscape.