On July 18, 2025, President Donald Trump signed into law the Guiding and Establishing National Innovation for U.S. Stablecoins Act of 2025 (the GENIUS Act or the Act), following its bipartisan passage by the Senate on June 17 (68–30) and the House on July 17 (308–122). 

In this alert, Winston’s Financial Innovation & Regulation Practice takes a closer look at the recent joint statement by the Office of the Comptroller of the Currency (OCC), the Federal Reserve Board (FRB), and the Federal Deposit Insurance Corporation (FDIC) regarding the safekeeping of crypto-assets and implications for the financial services industry.

The OCC, FRB, and FDIC have issued a joint statement clarifying the regulatory expectations applicable to the safekeeping of crypto-assets by banking organizations. The interagency statement offers a structured articulation of how legacy supervisory principles are expected to operate in the emerging context of crypto-asset safekeeping by banking organizations.

In the absence of active enforcement by federal banking regulators, many financial institutions are choosing this moment to take a second look at their compliance policies and procedures. Recent administrative actions implicating access to financial services may particularly require financial institutions to reevaluate their Consumer Due Diligence (CDD) procedures and Consumer Identification Program (CIP).