Heavy news! The Office of the Comptroller of the Currency has approved national banks to hold Crypto Assets to pay network fees.

In November 2025, the Office of the Comptroller of the Currency (OCC) confirmed through Interpretative Letter No. 1186 that national banks can hold crypto assets on their balance sheets to pay for Blockchain network fees. This policy clarifies the amount of crypto assets banks are required to hold to support approved activities, categorizing such holdings as “incidental to banking activities.”

OCC explained that when banks operate on a Blockchain system, the use of native tokens to process transactions is an unavoidable requirement, which makes the holding of such assets compliant with federal banking laws. This move provides regulatory clarity for more financial services using Blockchain systems, while requiring banks to manage market, liquidity, cybersecurity, and legal operational risks.

OCC Crypto Assets Regulatory Framework and Compliance Requirements

The latest guidance from the Office of the Comptroller of the Currency (OCC) provides an important legal basis for national banks in the United States to engage in digital asset activities. According to the interpretive letter, the payment of network fees falls under the long-standing category of “banking activities incidental to banking,” a term used by the OCC to indicate that this activity can support the normal operations of banks. The regulators also compared this situation to past banking needs, such as holding foreign exchange or equity interests in payment systems to process transactions.

Banks may need to hold Crypto Assets when supporting custodial operations or acting as an agent for customers. OCC also stated that banks can use these assets when testing internal or third-party encryption platforms. In their words, “Holding Crypto Assets for this purpose is permissible when it supports other legitimate banking activities.” The guidance emphasizes that banks must manage market, liquidity, cybersecurity, legal, and operational risks, and the amount of Crypto Assets on the balance sheet should be kept to a minimum and aligned with the bank's capital structure.

Policy Background and Regulatory Trends

At the time of this letter's release, the OCC is under the leadership of Audit Chief Jonathan Gould, confirmed in mid-2025. Under Gould's leadership, the OCC has taken steps to allow banks to engage in more digital asset activities. The agency had previously released guidance allowing banks to operate Blockchain network nodes and provide digital asset custody services.

This new letter reinforces this trend and provides a framework for banks that hope to reduce their reliance on external service providers. It also gives banks more control over the technical aspects of blockchain services, as they can now hold the assets required to execute transactions. OCC stated that this move supports activities permitted under the “Guidance and Establishment of the National Stablecoin Innovation Act of the United States,” including the processing of network fees related to stablecoin transactions and other approved services.

Key Milestones in the Evolution of OCC Policies

Node Operation: Banks are now allowed to run Blockchain nodes.

Custody Services: Approved Digital Asset Custody Services

Network fees: New approved holding crypto assets to pay fees

Stablecoin rules: Being formulated under the GENIUS Act.

Risk Management: It is essential to manage risks such as market, liquidity, and cybersecurity.

Impact of Banking Services and Strategic Significance

The OCC's decision has far-reaching implications for the U.S. banking industry. First, it enables banks to participate more directly in the operation of blockchain networks, reducing reliance on third-party service providers. This independence not only helps to lower costs but also enhances operational efficiency and security controls. For banks actively expanding their crypto assets business, this means they can build a more complete service value chain.

From a competitive perspective, this policy may accelerate the digital transformation of the banking industry. Early adopters may gain a first-mover advantage, especially in areas such as Crypto Assets custody, cross-border payments, and Blockchain-based trade financing. At the same time, smaller community banks may also participate in this trend through collaborative models, sharing infrastructure and service capabilities. Industry analysts predict that within the next 12-18 months, we will see major national banks announcing specific Blockchain implementation plans.

Risk Control and Compliance Challenges

Although OCC provides regulatory approval, banks still face significant risk management challenges in the implementation process. Market risk arises from the volatility of crypto asset prices, and banks need to establish appropriate valuation and hedging mechanisms. Liquidity risk involves whether they can obtain enough crypto assets to pay network fees in a timely manner when needed, without significantly impacting market prices.

Cybersecurity risks are particularly prominent, and holding crypto assets private keys requires bank-level security solutions to prevent hacking attacks and internal misconduct. Legal risks include changes in regulatory requirements and issues related to cross-border business compliance. Operational risks involve transaction processing errors, system failures, and human mistakes. OCC clearly requires banks to incorporate these risks into their existing risk management frameworks and ensure that the amount of crypto assets held is aligned with the bank's capital structure and risk tolerance.

Industry Ecosystem and Partnerships

The new OCC policy is expected to foster a new financial services ecosystem. Traditional financial technology providers are accelerating the development of Crypto Assets management solutions that meet banking requirements, including custody services, key management, and transaction monitoring tools. Law firms and consulting companies are also starting to offer related compliance services to help banks navigate the regulatory requirements of this emerging field.

The cooperation between banks and native blockchain enterprises may deepen. Some banks may choose to establish strategic partnerships with experienced crypto assets service providers to accelerate capability building. Other banks may choose to acquire or invest in related startups to directly obtain technology and talent. This trend of convergence will further blur the boundaries between traditional finance and crypto finance, driving the entire industry toward a more integrated direction.

Future Outlook and Regulatory Evolution

The guidance from the OCC is part of a broader trend among federal banking regulators. The Federal Reserve, the Federal Deposit Insurance Corporation, and the Treasury are developing a new set of rules for stablecoin issuers under the GENIUS Act. During the rule-making process, the OCC's guidance has provided clarity for banks preparing to expand their crypto asset business.

The institution stated that paying network fees is a standard part of using these networks, and banks can now hold the assets they expect to need for this purpose. With the implementation of these policies, we may see more explanatory letters and guidance documents that further refine the scope and conditions of banks' participation in crypto assets activities. In the long term, this could lead to the U.S. banking industry regaining global leadership in the digital asset services sector.

When the OCC officials signed the explanatory letter numbered 1186, they may not have realized that they were writing a new chapter in the history of the American banking industry—moving from merely observing the crypto wave to being permitted to personally set sail. Those few lines of crypto assets on the bank's balance sheet may seem insignificant, but they actually represent a formal handshake between traditional finance and the blockchain world, signaling that the integration of these two parallel universes has finally entered the official agenda.

FAQ

What is the main purpose of OCC allowing banks to hold Crypto Assets?

Mainly used for paying network fees on the Blockchain, which is an inevitable requirement when banks operate and process transactions on the Blockchain system, belonging to activities “incidental to banking operations.”

What are the restrictions for banks holding crypto assets?

The holdings must be limited to the needs reasonably expected to support legitimate banking activities, kept to a minimum, in line with the bank's capital structure, and strictly manage various types of risks.

What impact does this policy have on bank customers?

Customers may enjoy more direct and lower-cost Blockchain-related services, and banks can reduce their reliance on third-party service providers, offering a more complete digital asset service value chain.

What is the legal basis for this OCC decision?

Based on the traditional category of “banking business adjuncts,” analogous to past precedents where banks held foreign exchange or stakes in payment systems, in compliance with relevant provisions of the Federal Banking Act.

What are the main risks faced by banks during implementation?

Including market risk, liquidity risk, cybersecurity risk, legal risk, and operational risk, must be incorporated into the existing risk management framework and effectively controlled.