OCC Clarifies Banks’ Role in Crypto Asset Transactions

The Office of the Comptroller of the Currency clarified that national banks can participate in risk-free principal crypto transactions without holding inventory, as stated in Interpretive Letter #1188.

This decision allows banks to act as intermediaries in cryptocurrency transactions, potentially boosting regulated liquidity without banks bearing price risks or holding proprietary inventory.

Potential Impact on Banks and Market Dynamics

Industry insiders are noting that this move could lead to a safer integration of crypto within traditional finance systems. Jake Chervinsky remarked, “The banking process is fundamentally different from proprietary trading,” emphasizing the brief holding period of crypto assets as a positive step for regulatory compliance.

With this clarification, banks will potentially enhance integrated crypto services. By not holding inventory, banks avoid market volatility risk associated with crypto price changes, focusing on enabling efficient transaction routing. Since this announcement, financial institutions can explore new ways to serve clients within legal frameworks, potentially boosting market liquidity.

“The process for banks participating in crypto trading is fundamentally different from proprietary trading… banks typically purchase crypto assets from clients during transactions and immediately transfer the positions to liquidity providers (LPs). Technically, they only hold ownership of the crypto assets for a very short period… From an economic substance perspective, this model falls under brokerage services.”

Historical Context, Price Data, and Expert Analysis

Did you know? The OCC’s interpretive letters have historically shaped crypto integration in banking, with IL 1188 expanding beyond early 2025 guidance on custody and executions.

Bitcoin (BTC) continues to experience fluctuations, with its current price at $87,215.87, a market cap of $1.74 trillion, dominance at 58.91%, and 24-hour trading volume over $41 billion. Prices have decreased 3.15% over the last 24 hours and 23.77% in 90 days, according to CoinMarketCap.

Coincu research emphasizes that this regulatory development might catalyze an increase in pre-approved intermediated crypto transactions, potentially sustaining demand for non-security crypto assets like Bitcoin and Ethereum in global markets.