The US Office of the Comptroller of the Currency has confirmed that national banks can hold and use cryptocurrency to pay blockchain network fees required for permissible activities.
OCC Outlines New Permissions for Banks
The US Office of the Comptroller of the Currency (OCC) has issued new policy guidance confirming that national banks may hold and use cryptocurrency to pay blockchain network fees, commonly known as gas fees. The clarification, released in Interpretive Letter 1186, references the Guiding and Establishing National Innovation for US Stablecoins (GENIUS) Act, which outlines circumstances in which banks may need to manage network fees on behalf of customers or as part of stablecoin-related activities.of their routine operations.
The OCC emphasized that maintaining reasonable amounts of crypto on balance sheets is acceptable when banks have a “reasonably foreseeable need” to cover fee-related obligations.
The letter concluded:
“The need for banks ‘to pay network fees to facilitate otherwise permissible crypto-asset activities and to hold, as principal, amounts of crypto-assets on balance sheet necessary to pay network fees for which the bank anticipates a reasonably foreseeable need is permissible for the bank.”
Ethereum Used as a Case Study
Blockchain networks typically require transactions to be paid in their native tokens, making some level of crypto holdings inevitable for institutions operating in this space.
To illustrate the challenges banks face, the OCC cited the Ethereum blockchain, noting that ETH must be used to settle transactions. Without holding ETH directly, users and institutions are often forced to pursue less efficient alternatives.
As the letter noted:
“Such a user would have to either maintain a separate ETH account, conduct a spot transaction on a crypto-asset exchange to obtain ETH prior to the transaction, engage with a third-party network fee-provider, or obtain ETH by some other method.”
The agency added that these steps could significantly increase costs as well as compound risks, especially in cases of operational complexity, asset price changes, and transactional delays.
OCC Reverses Years of Hesitation
The OCC’s latest position marks a clear pivot away from earlier caution around crypto engagement. With President Trump’s pro-crypto stance shaping regulatory priorities, the agency, now led by Trump-appointed Comptroller Jonathan Gould, confirmed in July that it has accelerated efforts to integrate digital assets into the regulated banking system.
The bureau has already confirmed that US banks may buy and sell crypto assets on their own behalf. It has also removed references to “reputation risk” in its supervisory materials, though it stressed that expectations around risk management standards remain unchanged.
Disclaimer: This article is provided for informational purposes only. It is not offered or intended to be used as legal, tax, investment, financial, or other advice