The OCC has clarified that national banks and federal savings associations can buy and sell crypto assets on behalf of customers and outsource crypto-asset custody and execution services to third parties, provided they implement appropriate third-party risk management practices.

This guidance was issued in Interpretive Letter #1184 on May 7, 2025, reaffirming and expanding on Interpretive Letter 1170, which previously confirmed banks' authority to provide crypto-asset custody services in fiduciary or non-fiduciary capacities. The OCC recognizes crypto-asset custody as a modern form of traditional bank custody activities and allows banks to use sub-custodians, subject to proper oversight.