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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
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
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
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
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
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
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
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
The FDIC has rescinded an earlier Financial Institution Letter establishing a prior notification requirement for FDIC-supervised institutions that wish to engage in specified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
On March 28, the Federal Deposit Insurance Corporation (FDIC) rescinded Biden administration guidance related to state-chartered banks' participation in "crypto-related activities" and published a new interpretation of the...more
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
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
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
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
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
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
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
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
Ask any centralized cryptocurrency firm to name one of their biggest priorities or challenges—and then count the number of times they mention bank partnerships. For crypto firms, the loss of, or failure to acquire, a bank...more
Point-of-sale financing arrangements payable in four or fewer interest-free installments, known as buy now, pay later (BNPL) arrangements, have soared since their initial breakthrough during the pandemic. Unlike conventional...more
On January 27, the Federal Reserve Board (FRB) announced that it unanimously voted to deny a crypto firm’s application to become a member of the Federal Reserve System. This denial ends the crypto firm’s 27-month effort to...more
On September 15, 2020, the Conference of State Bank Supervisors (CSBS) announced a “one company, one exam” program for examinations of money services businesses. These businesses, spanning from money transmitters like PayPal...more
The OCC Announces New Acting Comptroller and Includes FinTech Charters Among Focuses - On May 29, 2020, the Office of the Comptroller of Currency (OCC), the primary federal regulator of national banks, announced Brian P....more