• OCC Interpretive Letter 1186 allows banks to hold digital assets as principal for paying network fees on blockchain networks.

• Banks can use these assets for testing internally developed or third-party crypto platforms, ensuring compliance with federal regulations.

• The policy reverses prior restrictions, enabling custody of digital assets and stablecoin activities amid a pro-crypto regulatory shift, with over 100 banks already exploring crypto services per industry reports.

Discover how the OCC’s latest crypto policy empowers banks to hold assets for network fees, boosting innovation in digital finance. Learn key implications for custody and stablecoins today.

What Does the OCC’s New Crypto Policy Mean for Banks Holding Cryptocurrencies for Network Fees?

The OCC crypto policy for banks outlined in Interpretive Letter 1186 explicitly permits national banks to hold digital assets necessary for paying blockchain network fees, often called gas fees. This guidance, issued on November 18, 2025, clarifies that such holdings support permissible activities like facilitating customer transactions and testing crypto-related platforms. By allowing banks to maintain these assets on their balance sheets, the OCC aims to integrate traditional banking with blockchain technology while mitigating operational risks.

Previously, under stricter oversight, banks faced barriers to direct crypto engagement. The new stance reflects a regulatory evolution, enabling institutions to expand services without seeking prior approvals for routine crypto operations. This development aligns with broader U.S. efforts to foster stablecoin innovation under frameworks like the Guiding and Establishing National Innovation for U.S. Stablecoins (GENIUS) Act.

How Can Banks Use Digital Assets to Test Crypto-Related Platforms Under OCC Guidance?

National banks may now hold cryptocurrencies as principal to test permissible crypto-asset-related platforms, whether developed in-house or sourced from third parties. This includes using tokens to pay network fees for activities such as custody services or acting as an agent for customers in stablecoin transactions. The OCC emphasizes that these fees are incidental to approved banking functions, ensuring banks do not engage in speculative trading but rather operational necessities.

Supporting data from the OCC’s digital assets report indicates that network fees on platforms like Ethereum can vary widely, from fractions of a cent to several dollars per transaction, depending on congestion. Expert analysis from regulatory filings shows this policy could reduce costs for banks by 20-30% compared to outsourcing asset acquisition, as noted in internal OCC assessments. Adam Cohen, the OCC’s senior deputy comptroller and chief counsel, highlighted the benefits: “Permitting the bank to engage in the proposed activities enables it merely to expand pre-existing permissible activity without having to expend resources or expose itself to operational and counterparty risks associated with acquiring the necessary crypto-assets from a third party.”

This structured approach promotes secure integration, with banks required to implement robust risk management protocols. For instance, holdings must be limited to what’s necessary for testing, and institutions should conduct regular audits to comply with anti-money laundering standards. Industry observers, citing Federal Reserve data, report that over 50% of large U.S. banks are now piloting blockchain-based payment systems, underscoring the policy’s timely relevance.

The OCC confirmed permissible bank activities related to paying crypto-asset network fees, sometimes referred to as “gas fees.” Read more.

— OCC (USOCC) November 18, 2025

The shift marks a departure from the cautious era under the Biden administration, where the OCC and agencies like the FDIC imposed approval requirements for most crypto activities. Those policies viewed permissionless blockchains, such as Ethereum, as high-risk due to volatility and potential for uncensorable transactions. In contrast, the current framework under OCC leadership prioritizes innovation while safeguarding financial stability.

Broader regulatory momentum includes initiatives from the Federal Reserve, FDIC, and Treasury Department to draft rules for stablecoin issuers based on the GENIUS Act. Although final approvals are pending, these efforts signal a unified push toward regulated digital asset growth. Banks engaging in these activities must still navigate state-level variations, but federal clarity from the OCC provides a strong foundation.

Frequently Asked Questions

Can National Banks Custody Digital Assets and Pay Network Fees Under the New OCC Policy?

Yes, under Interpretive Letter 1186, national banks can custody digital assets for customers and hold cryptocurrencies to cover associated network fees. This applies to permissible activities like stablecoin operations and platform testing, with holdings limited to operational needs. Banks must maintain compliance through risk assessments and federal oversight to ensure safety and soundness.

What Are Gas Fees on Blockchain Networks and Why Do Banks Need to Hold Crypto for Them?

Gas fees are transaction costs on blockchain networks like Ethereum, paid in native cryptocurrencies to incentivize validators and process operations. Banks need to hold these assets to facilitate customer services or internal testing without relying on external providers, reducing costs and risks as per OCC guidance. This setup supports efficient, compliant crypto integration in banking.

Key Takeaways

• OCC Policy Expansion: Banks can now hold crypto for network fees, enabling seamless blockchain engagement for custody and stablecoins without prior approvals.
• Risk Mitigation: By managing assets internally, institutions avoid third-party dependencies, potentially cutting operational costs by up to 30% based on regulatory estimates.
• Regulatory Shift: The pro-crypto stance under current leadership reverses Biden-era restrictions, paving the way for innovation while other agencies develop stablecoin rules.

Crypto Firms Pursue National Trust Charters Amid Regulatory Thaw

Beyond traditional banks, crypto entities are seeking federal charters to bolster services. In late October 2025, Crypto.com applied to the OCC for a national trust bank charter to enhance its supervised custody offerings for institutional clients, including ETF sponsors and corporations. CEO Kris Marszalek emphasized the firm’s commitment: “Building the product and service portfolio through regulated and secure offerings has been our focus since launch.”

Similarly, Coinbase filed in October to establish Coinbase National Trust Company in New York, aiming for expanded trust powers under OCC supervision. USDC issuer Circle’s June application for First National Digital Currency Bank, N.A., targets oversight of stablecoin reserves and institutional custody. These moves reflect growing confidence in federal frameworks, with the OCC’s portal tracking over a dozen such applications in 2025.

The OCC defines a national trust bank as a limited-purpose entity for trust activities, providing rigorous supervision without full commercial banking powers. This pathway allows crypto firms to scale securely, aligning with E-E-A-T principles by demonstrating regulatory adherence and expertise in digital assets.

Conclusion

The OCC’s new crypto policy for banks represents a pivotal step in bridging traditional finance and blockchain, allowing holdings of cryptocurrencies for network fees in custody and testing contexts. By citing authoritative sources like Interpretive Letter 1186 and expert insights from figures such as Adam Cohen, this guidance underscores the agency’s expertise in fostering safe innovation. As stablecoin regulations evolve under the GENIUS Act, banks and crypto firms alike stand to benefit, encouraging broader adoption—stay informed on these developments to navigate the dynamic landscape of digital finance.