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 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 Office of the Comptroller of the Currency (OCC) recently entered into a consent order with the first federally-chartered digital asset bank, Anchorage Digital Bank (Anchorage Digital), for “fail[ing] to adopt and implement a compliance program that adequately covers the required Bank Secrecy Act/Anti-Money Laundering (BSA/AML) program elements.”