The Office of the Comptroller of the Currency (OCC) announced on Dec. 9 that national banks may engage in riskless principal crypto-asset transactions, clarifying how institutions can intermediate offsetting trades without holding crypto-assets in inventory. The update defines the permissible scope of this banking activity.

The announcement states:

A national bank may engage in riskless principal crypto-asset transactions as part of the business of banking.

Interpretive Letter 1188 explains that a bank may act as principal with one customer while simultaneously entering an offsetting transaction with another, functioning as an intermediary equivalent to a broker acting as agent. The OCC defines “riskless” to mean that the bank executes both sides of the transaction only when an immediate, offsetting order exists, allowing the purchase and sale to occur effectively simultaneously and preventing the bank from holding crypto-assets in inventory.

The letter notes that only nominal settlement or credit risk is involved and that these transactions resemble longstanding brokerage and intermediation practices across securities and derivatives. It further details how the activity aligns with recognized banking functions, including customer-driven custody services and technology-neutral regulatory principles, while emphasizing the benefits of regulated execution channels for market participants.

Read more: OCC Affirms Banks May Hold Crypto to Pay Network Fees

The interpretive letter also outlines the risk profile, stating that counterparty credit risk remains the primary exposure and that banks typically liquidate assets quickly in any settlement default. It highlights that national banks already maintain infrastructure for other permissible crypto activities—such as custody, stablecoin-related functions, and blockchain network fee operations—which supports effective liquidation and settlement processes. While confirming permissibility, the OCC stressed that banks must conduct these transactions safely, soundly, and in full compliance with applicable law, and that examiners will incorporate oversight of riskless principal crypto-asset activities into ongoing supervision.

• What crypto activity did the OCC newly affirm for national banks?
  The OCC affirmed that national banks may conduct riskless principal crypto-asset transactions.
• How does Interpretive Letter 1188 describe bank participation?
  It explains banks can intermediate offsetting customer trades as principals with only nominal settlement risk.
• What primary risk does the OCC highlight in these transactions?
  The OCC identifies counterparty credit risk as the main exposure.
• What conditions must banks meet when performing these crypto transactions?
  Banks must operate safely, soundly, and in full compliance under ongoing examiner oversight.

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