Key Points
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U.S. regulators have clarified that national banks can broker crypto trades as riskless principals without holding assets.
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JPMorgan’s exploration of crypto trading highlights growing bank interest in spot markets.
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Crypto exchanges face margin pressure in retail spot trading but may benefit as infrastructure providers.
The U.S. banking regulator has quietly opened the door for Wall Street banks to step deeper into crypto trading, a shift that could reshape how Americans buy and sell digital assets — and intensify competition for crypto-native exchanges.
A regulatory inflection point emerged after Bloomberg reported that JPMorgan Chase is exploring crypto trading services for institutional clients. The move follows new guidance from the Office of the Comptroller of the Currency (OCC) clarifying that national banks may facilitate certain crypto transactions under existing banking law.
Banks Get a Clearer Path Into Crypto Trading
At the center of the shift is an OCC interpretive letter issued on Dec. 9, which confirmed that national banks can engage in so-called “riskless principal” crypto transactions. Under this model, a bank can intermediate a crypto trade between buyers and sellers without holding digital assets on its balance sheet or taking market risk.
The guidance effectively frames crypto brokerage as part of the “business of banking,” allowing banks to earn fees from execution and settlement while avoiding the volatility that has historically deterred them from spot markets.
For large banks already embedded in capital markets, this removes a major legal ambiguity. “Armed with regulatory legitimacy and the trust that accompanies it, banks are poised to absorb a meaningful portion of order flow,” said Burçak Ünsal, managing partner at ÜNSAL Attorneys at Law.
A New Competitive Dynamic for Crypto Exchanges
The implications for crypto-native exchanges are significant. Retail-focused platforms such as Coinbase, Gemini and Kraken have built businesses around spot trading, custody and fiat on-ramps — precisely the services banks are now positioned to offer to their existing customers.
Banks enjoy structural advantages: deep client relationships, balance-sheet credibility and regulatory trust. By acting as riskless principals, they can provide crypto access without inventory exposure, compressing margins in the most stable segment of exchange revenue.
“This doesn’t kill exchanges, but it pressures their core,” said Keneabasi Umoren, a crypto market analyst. “U.S. spot trading and custody are exactly where banks can compete most effectively.”
Banks Have Been Preparing Quietly
The OCC clarification did not emerge in a vacuum. Over the past several years, major banks have laid groundwork through infrastructure and partnerships rather than direct trading.
JPMorgan has built blockchain-based settlement rails through its Kinexys platform and JPM Coin. Goldman Sachs has restarted crypto derivatives trading for institutional clients. BNY Mellon has rolled out digital-asset custody. These initiatives now look less like experiments and more like precursors to full brokerage-style offerings.
According to Mati Greenspan, founder of Quantum Economics, the shift reflects consumer behavior as much as regulation. “Many users will prefer buying bitcoin from their bank rather than opening an account at a standalone exchange,” he said.
Not Exchanges — But Close Enough
Importantly, the OCC has not designated banks as crypto exchanges. Banks are expected to proceed conservatively, offering a limited set of highly liquid assets such as bitcoin, ether and regulated stablecoins, while relying on crypto-native firms for liquidity, routing and market-making.
That dynamic could push exchanges further toward infrastructure roles — powering execution, custody and global liquidity — rather than competing solely for retail order flow.
“The winners will be exchanges that adapt by supplying the plumbing,” said Kevin Lee, chief business officer at Gate. “This is pressure, but also validation.”
What Comes Next
The OCC’s signal represents a structural shift rather than a one-off policy change. As regulatory clarity improves, banks are likely to expand cautiously, starting with institutional clients and wealth platforms before moving downmarket.
For crypto exchanges, the challenge is clear: differentiate beyond basic spot trading or risk seeing margins squeezed by institutions with deeper trust and broader distribution. The next phase of crypto adoption may look less like disruption — and more like convergence.
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