Key Points
• The OCC affirmed that national banks may execute crypto transactions as riskless principals, matching customer orders without holding crypto assets.
• Banks must maintain strict compliance and risk-management procedures, especially around settlement and counterparty exposure.
• The move accelerates the normalization of crypto within U.S. banking, potentially reshaping institutional trading and custody models.
The U.S. Office of the Comptroller of the Currency (OCC) has issued long-awaited guidance confirming that national banks may facilitate cryptocurrency transactions as riskless principals — a development that could accelerate Wall Street’s entry into crypto brokerage services. The move brings digital assets further into the regulatory mainstream, allowing banks to match customer buy and sell orders without holding crypto on their balance sheets.
The interpretive letter, released Tuesday, marks the most significant expansion of bank-permissible crypto activities since the OCC’s earlier guidance on digital custody. It also signals a growing alignment between Washington regulators and the banking sector on how digital assets should be integrated into traditional market infrastructure.
Banks Gain Approval for Riskless Principal Crypto Transactions
Under the new guidance, banks may act as intermediaries between two customer orders, simultaneously purchasing and selling the same crypto asset in a way that eliminates market exposure — a model identical to long-established riskless principal trading in equities and fixed income.
The OCC emphasized that such activity fits squarely within the statutory definition of the “business of banking,” citing 12 U.S.C. § 24. The structure allows banks to offer crypto execution services without directly managing the custodial risks typically associated with digital-asset balance sheet holdings.
Several prospective bank applicants had argued that offering fully regulated crypto execution services would meet rising customer demand, particularly as more institutions seek exposure to tokenized assets and blockchain-based settlement rails.
By allowing banks to intermediate these trades, the OCC noted, customers gain the ability to transact through a regulated channel rather than relying solely on “non-regulated or less regulated options,” an implicit nod to ongoing concerns about unregistered exchanges and offshore platforms.
Risk Controls Required as Banks Enter a New Market
The regulator’s letter cautioned that riskless principal trading does not eliminate all risks. Settlement risk — a subset of counterparty credit risk — remains the most material exposure, particularly in markets where finality of settlement varies across blockchain networks.
Still, the OCC argued that banks are well-equipped to manage such risks, given their long history of handling counterparty exposure in securities and derivatives markets.
Institutions pursuing this line of business must demonstrate that crypto trading activities are legally permissible under their charter, fall within risk-management capacity, and comply with all anti-money laundering and consumer-protection rules.
The interpretive letter stopped short of allowing banks to offer full-scale crypto market-making or proprietary trading, maintaining the OCC’s cautious but gradually warming stance on digital-asset integration.
Regulatory Signals Suggest a Normalizing Path for Crypto Banking
The guidance comes just one day after Acting Comptroller Jonathan Gould said crypto-focused firms seeking a federal bank charter should be evaluated using the same standards as traditional institutions. Gould noted that banks have provided electronic custody services “for decades,” arguing that the evolution toward digital assets is a natural extension of existing capabilities.
This shift in tone reflects a broader regulatory recalibration in Washington, where lawmakers and regulators increasingly recognize that digital assets are moving into mainstream capital markets, regardless of policy pacing.
For banks, the new interpretive clarity offers both opportunity and caution. Institutions can now build crypto execution services leveraging their regulatory credibility, but must navigate the operational and reputational risks that more volatile asset classes introduce.
Looking Ahead: A Bridge Between Finance and Digital Markets
The OCC’s decision positions banks to compete directly with crypto-native exchanges, potentially reshaping the execution landscape for institutional clients. If banks adopt these capabilities at scale, crypto trading could migrate into environments with stronger controls, more rigorous oversight and deeper liquidity pools.
The larger question is whether banks will leverage this approval to push further into tokenization, settlement technology and digital custody in 2026. As regulatory clarity improves, the momentum toward convergence between traditional finance and crypto markets appears increasingly difficult to reverse.
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