Non-Fungible Insights: Blockchain Decrypted

On May 7, 2025, the Office of the Comptroller of the Currency (OCC) published Interpretive Letter 1184 (“IL 1184”), which confirms that national banks may execute and settle digital asset trades on behalf of their customers, so long as the bank acts in an agency capacity and the activity is conducted in a safe and sound manner.

On April 24, 2025, the Federal Reserve Board (Board) announced that it had withdrawn key supervisory guidance published during the prior Administration that, for more than two years, had constrained state member banks and other Board-supervised banking organizations from engaging in digital asset activities.

On February 23, 2023, the Board of Governors of the Federal Reserve System, the Federal Deposit Insurance Corporation, and the Office of the Comptroller of the Currency (collectively, the “agencies”) issued their second joint statement of the year regarding crypto-asset market vulnerabilities.

In this more recent joint statement, the agencies have drawn their attention to the liquidity risks created by funding from crypto-asset-related entities, and the methods to mitigate such risks.

On January 3, 2023, the Board of Governors of the Federal Reserve System, the Federal Deposit Insurance Corporation, and the Office of the Comptroller of the Currency issued a joint statement on crypto-asset risks to banking organizations.

The recent cessation of operations by some cryptocurrency exchange companies has led the Federal Deposit Insurance Company (FDIC) to increase its scrutiny of bank/digital asset partnerships, particularly of how those partnerships are marketed and the extent of federal deposit insurance coverage.