On July 22, 2020, the Office of the Comptroller of the Currency published an interpretive letter clarifying that providing cryptocurrency custody services to customers is a permissible activity for national banks and federal savings associations.
This letter marks an important milestone in the expansion of permissible banking activities related to digital assets. The letter concludes that cryptocurrency custody services fall within previously recognized authorities to engage in safekeeping and custody activities, and that national banks may offer these services in a fiduciary or non-fiduciary capacity. These services also include a broad range of custody-related services in relation to the cryptocurrency a national bank is custodying, including facilitating the customer’s cryptocurrency and fiat currency exchange transactions, transaction settlement, trade execution, recording keeping, valuation, tax services, reporting, or other appropriate services.
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