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Digital Assets Regulatory Requirements Office of the Comptroller of the Currency

Mayer Brown

OCC Reiterates Full Scope of Crypto Custody Authority of Banks It Regulates

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On May 7, 2025, the Office of the Comptroller of the Currency (“OCC”) issued Interpretative Letter 1184 (“IL 1184”) confirming that national banks and federal savings associations may provide cryptocurrency custody...more

DLA Piper

Blockchain and Digital Assets News and Trends – May 2025

DLA Piper on

This periodic bulletin is designed to help companies identify important legal developments governing the use and acceptance of blockchain technology, smart contracts, and digital assets. While the use cases for blockchain...more

Orrick, Herrington & Sutcliffe LLP

Acting Comptroller discusses importance of financial inclusion

On May 8, Acting Comptroller of the Currency Rodney E. Hood spoke on his four priority areas: financial inclusion, reducing regulatory burdens, bank-fintech partnerships, and digital assets. He emphasized that financial...more

Orrick, Herrington & Sutcliffe LLP

OCC clarifies crypto-asset activities in interpretive letter

On May 7, the OCC clarified permissible activities for national banks and federal savings associations regarding crypto-asset custody and execution services by publishing Interpretive Letter 1184. This letter confirmed...more

Latham & Watkins LLP

OCC Affirms Banks Can Engage in Crypto Custody and Execution Activities

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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

McGuireWoods LLP

Banks May Provide Cryptocurrency Transaction and Custody Services, but OCC Has Yet to Provide Clear Compliance Requirements

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On May 7, 2025, the Office of the Comptroller of the Currency (“OCC”) issued a follow up to its July 2020 Interpretative Letter 1170, which allowed national banks to provide cryptocurrency custody services to their customers....more

K&L Gates LLP

Federal Banking Regulators Adopt a Permissive Stance on Cryptocurrency

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The federal banking regulators have each recently adopted a more permissive approach to the regulation of cryptocurrency activities within the banking sector. The Office of the Comptroller of the Currency (OCC), the Federal...more

Nutter McClennen & Fish LLP

Nutter Bank Report: April 2025

The Federal Reserve has announced multiple decisions to rescind existing requirements for crypto-asset activities. The April 24 announcement included the rescission of a 2022 supervisory letter that required state member...more

Ballard Spahr LLP

OCC, FDIC eliminating ‘reputational risk’ from supervision, examinations

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The OCC has removed “reputational risk” from its handbooks and guidance and the FDIC is moving to do the same. ...more

Mayer Brown

FDIC Streamlines Process for Cryptocurrency Activities by Banks It Regulates and Speculates on Additional Permissible Activities

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On March 28, 2025, the Federal Deposit Insurance Corporation (FDIC) issued guidance on state nonmember bank and state savings association participation in certain cryptocurrency activities (“FIL-7-2025”). ...more

Jones Day

FDIC Rescinds Prior Notification Requirement for Banks' Permissible Crypto Activities

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The FDIC has rescinded an earlier Financial Institution Letter establishing a prior notification requirement for FDIC-supervised institutions that wish to engage in specified crypto-related activities and has clarified that...more

Katten Muchin Rosenman LLP

Banking Agencies Begin Publishing Updated Crypto Guidance

On March 28, the Federal Deposit Insurance Corporation (FDIC) rescinded Biden administration guidance related to state-chartered banks' participation in "crypto-related activities" and published a new interpretation of the...more

Brownstein Hyatt Farber Schreck

Regulating Digital Dollars: How Federal Bills Stack Up

In November of 2021, the President’s Working Group on Financial Markets, joined by the Federal Deposit Insurance Corporation (FDIC) and the Office of the Comptroller of the Currency (OCC), issued a report formally...more

Mayer Brown

Congress Moves Forward on Stablecoin Legislation: The US Senate Banking Committee Approves the GENIUS Act

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On March 13, 2025, the US Senate Banking Committee passed the Guiding and Establishing National Innovation for US Stablecoins Act of 2025 or “GENIUS Act,” out of committee by a vote of 18-6....more

Ballard Spahr LLP

Crypto Clarity: OCC’s New Guidelines Pave the Way for Banking Innovation

Ballard Spahr LLP on

On March 7, 2025, the Office of the Comptroller of the Currency (“OCC”) released Interpretive Letter 1183, marking a pivotal change in regulatory guidance for national banks and federal savings associations engaging in...more

Latham & Watkins LLP

OCC Affirms Regulated Entities Can Engage in Crypto and Stablecoin Activities

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In a break from restrictive Biden-era policies, OCC-supervised banks may now engage in crypto without supervisory nonobjection, potentially opening new avenues for innovation....more

Sheppard Mullin Richter & Hampton LLP

OCC Clarifies Banks’ Role in Cryptocurrency Activities

On March 7, the OCC issued Interpretive Letter 1183 and an accompanying statement affirming prior guidance regarding whether national banks and federal savings associations may engage in cryptocurrency-related activities,...more

Troutman Pepper Locke

OCC Clarifies Bank Authority to Engage in Certain Cryptocurrency Activities

Troutman Pepper Locke on

On March 7, the Office of the Comptroller of the Currency (OCC) issued a significant update regarding the involvement of national banks and federal savings associations in cryptocurrency activities. Interpretive Letter 1183...more

Jones Day

OCC Eases Some Restrictions on Bank Digital Asset Activities

Jones Day on

In recent years, U.S. federal bank regulators significantly limited banks' authority to engage in crypto-asset activities, including participating in public blockchains, owning digital assets as principal, and even providing...more

Davis Wright Tremaine LLP

OCC Rescinds Required Supervisory "Non-Objection" Preclearance for Permissible Crypto-Related Activities

The OCC has reiterated that certain crypto-related activities—crypto-asset custody, distributed ledger, and stablecoin activities—previously determined to be permissible remain so. The OCC has also rescinded a Biden-era...more

Paul Hastings LLP

Crypto-Focused Congress Drops Two New Stablecoin Bills

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Last week, both chambers of Congress presented drafts of legislation intent on regulating payment stablecoins. The GENIUS Act, presented by Sens. Tim Scott, Bill Hagerty, Cynthia Lummis and Kirsten Gillibrand, arrived on...more

Latham & Watkins LLP

2020 Digital Asset Regulatory Lookback (US Edition)

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Regulators once again offered piecemeal guidance, while focusing on risks and enforcement. Meanwhile, innovation and institutional adoption took off. Last year, Latham & Watkins sounded a hopeful note that 2020 would provide...more

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