The Office of the Comptroller of the Currency has issued guidance permitting national banks to act as intermediaries in low-risk cryptocurrency trades. Interpretive Letter 1188 confirms that such riskless principal transactions fit within the business of banking. This move aligns with recent regulatory efforts to integrate digital assets into traditional finance.
On December 9, 2025, the Office of the Comptroller of the Currency (OCC) published Interpretive Letter 1188, clarifying that national banks may engage in riskless principal transactions involving crypto-assets. These transactions occur when a bank buys a crypto-asset from one customer and simultaneously sells it to another, without holding the assets in inventory. The OCC describes this as the legal and economic equivalent of a broker acting as an agent, neutralizing market risk through offsetting trades while retaining limited credit risk.
The letter extends existing permissions for securities to non-security crypto-assets, analyzing the activity under four factors: its similarity to traditional banking functions like brokerage and custody, benefits to banks and customers through regulated access, manageable risks such as settlement defaults, and compatibility with state regulations. "In these activities, the bank neutralizes its market risk through offsetting transactions but retains credit risk due primarily to the ongoing financial obligations of the parties to the transaction," the OCC stated. Banks must conduct these activities in a safe and sound manner, subject to supervisory review.
This guidance builds on prior OCC actions easing crypto restrictions. In March 2025, the agency removed advance approval requirements for certain crypto operations. Earlier letters include 1183, confirming custody, stablecoin activities, and node verification; 1184, allowing banks to buy and sell custody-held assets and outsource services; and 1186, permitting payment of crypto network fees and holding assets as principal. Under Comptroller Jonathan Gould, confirmed in July 2025, the OCC has approved 14 new bank charters this year, including for crypto firms like Coinbase and Circle.
Recent bank actions reflect this trend. Last week, Bank of America enabled wealth management clients to allocate 1%–4% of portfolios to digital assets across its platforms. On the same day as the letter, PNC Bank launched direct bitcoin trading for eligible private clients via a Coinbase partnership.
