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On May 7, the OCC issued Interpretive Letter 1184, reaffirming that national banks and federal savings associations may provide cryptocurrency custody and execution services, including through sub-custodians. The OCC...more
The federal banking agencies continue to open the channels for regulated entities to engage in digital asset activities. On May 7, 2025, the Office of the Comptroller of the Currency (OCC) published Interpretive Letter...more
As federal regulation remains patchy, firms may want to consider a New York state charter as a potential avenue to expand digital asset offerings in a compliant manner. On March 22, 2024, WisdomTree, Inc., a global asset...more
Institutional investors, corporations, exchanges, individuals, and crypto miners all have strong demand for crypto custody services, as provided by special market participants. These services intend to safeguard customers’...more
Two recent actions by the Office of the Comptroller of the Currency (OCC) - one enforcement action and one interpretive note - focus attention on the kinds of anti–money laundering (AML) controls needed for banks to custody...more
On Wednesday, July 22, 2020, Acting Comptroller of the Currency Brian Brooks reaffirmed his interest in being seen as an agent of modernization in a letter clarifying the authority of national banks and federal savings...more
On July 22, 2020, the Office of the Comptroller of the Currency (the “OCC”) issued Interpretive Letter No. 1170 (the “Letter”) authorizing national banks and federal savings associations to provide cryptocurrency custody...more
On July 22, 2020, the Office of the Comptroller of the Currency (OCC) issued an interpretive letter confirming that national banks and federal savings associations (banks) may provide cryptocurrency custody services to...more
On April 29, 2019, the Office of the Comptroller of the Currency (OCC) issued an Advance Notice of Proposed Rulemaking (ANPR) to solicit comment on whether it should issue a formal proposal to expand the reach of its...more