The U.S. Office of the Comptroller of the Currency (OCC) has clarified that U.S. national banks may hold crypto on their balance sheets to pay blockchain network fees and test crypto platforms.
The guidance, issued in interpretive letter No. 1186, states that banks can keep crypto on hand to cover network fees and to facilitate internal or third-party platform testing, noting that blockchain networks require native tokens to process transactions.
The OCC said banks can hold the tokens they reasonably anticipate needing, including paying fees as part of crypto custody services or facilitating client transactions.
“Paying network fees is a necessary part of doing business on blockchain networks,” the OCC said, adding that “holding crypto for this purpose is permissible when it supports otherwise lawful banking activities.”
The agency emphasizes that these activities are incidental to the business of banking, meaning they are lawful as long as they help banks serve customers or operate efficiently.
The OCC drew parallels to historical practices such as holding foreign currency or shares in payment systems to facilitate transactions.
Banks are expected to manage risks carefully, including operational, market, liquidity, cybersecurity, and legal risks, and the amount of crypto held should remain minimal relative to the bank’s capital.
The letter is issued under Comptroller Jonathan Gould, a Trump appointee confirmed in July 2025.
Under his tenure, the OCC has become more crypto-friendly, with earlier guidance allowing banks to act as nodes on blockchain networks, offer crypto custody services, and work with stablecoins.
Broader rules for stablecoin issuers under the GENIUS Act are still being drafted.
The OCC’s move signals that U.S. regulators are willing to let banks participate in crypto safely and efficiently, potentially accelerating adoption as more banks explore digital assets.
Earlier this year, the OCC issued guidance (Interpretive Letter 1184) allowing national banks and federal savings associations to offer cryptocurrency custody and trading services.
Banks can buy and sell digital assets on behalf of customers, outsource crypto activities to third parties, and provide related services like recordkeeping, tax reporting, and compliance.
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