The Office of the Comptroller of the Currency (OCC) has issued Interpretive Letter 1188, confirming that national banks may engage in "risk-neutral" cryptocurrency transactions. This means banks can act as intermediaries, offsetting trades with both buyers and sellers, without the need to hold cryptocurrency inventories.
This policy shift is not an isolated event, but rather part of a broader regulatory transformation under the Trump administration’s pro-crypto stance. Previously, in May 2025, the OCC allowed banks to provide crypto asset custody and execution services without prior approval.
01 Regulatory Shift
U.S. banking regulation is undergoing a quiet revolution. On November 18, 2025, the OCC issued Interpretive Letter 1186, confirming that banks may hold the necessary amount of crypto assets to pay blockchain network fees.
This marks a sharp contrast to the regulatory posture during the Biden administration, when agencies explicitly discouraged banks from entering the crypto asset space.
Just three weeks later, the OCC followed up with Interpretive Letter 1188, clearly permitting banks to participate in "risk-neutral" cryptocurrency transactions. In this model, banks serve as intermediaries, offsetting trades between buyers and sellers without holding crypto inventories.
02 Transaction Mechanism
Under the new rules, U.S. banks are authorized to act as intermediaries in crypto transactions—a business model known as "risk-neutral principal" trading. In this framework, banks operate as brokers, buying crypto assets from one party while simultaneously selling to another.
Banks generally do not hold crypto assets during this process, except in special circumstances. The OCC emphasizes that banks must conduct these activities in a safe and sound manner and comply with all applicable laws.
For banks, this new policy resolves a longstanding operational challenge. Previously, when conducting on-chain transactions, banks lacked clear authorization to hold native crypto assets and had to rely on third parties to pay gas fees or resort to off-chain workarounds.
03 Dual Impact
This regulatory change is having a dual impact on both the traditional banking sector and the crypto industry. For banks, the new rules remove key barriers to offering stablecoin custody, tokenized deposits, and similar services.
The banking landscape is undergoing structural adjustments. The OCC regulates only national banks, while the Federal Reserve continues to classify crypto as a "unsafe and unsound" major asset, creating policy divergence for state member banks.
Meanwhile, the crypto industry is seeing unprecedented opportunities for institutional participation. Greater regulatory clarity lowers the entry threshold for traditional financial institutions in the digital asset market. As more institutional investors enter, market liquidity and stability are expected to improve.
04 Restrictions and Challenges
Despite a more relaxed regulatory environment, banks still face multiple restrictions and challenges in the crypto asset space. The new rules make it clear that banks may only hold crypto assets strictly for operational needs, prohibiting unlimited speculation or holding them as investment assets.
Banks must adhere to rigorous risk management requirements, including market risk, liquidity management, and standard anti-money laundering controls. Price volatility in tokens like Bitcoin and Ethereum may affect the stability of banks’ balance sheets.
Capital adequacy has become a key threshold for banks entering crypto activities. According to the Federal Deposit Insurance Corporation (FDIC), banks must meet higher capital standards to participate in crypto-related business.
05 A New Market Landscape
This regulatory shift marks a major milestone as the traditional financial system embraces on-chain operations. As the regulatory framework matures, the crypto industry is evolving from being purely technology-driven to a dual focus on regulation and technology.
The relationship between banks and crypto exchanges may shift from competition to collaboration and complementarity. Banks can leverage their vast client bases and regulatory credibility, while exchanges offer technical expertise and deep liquidity.
For investors, this change means more diverse channels for accessing crypto assets and greater security. Bank involvement will boost market acceptance and recognition of cryptocurrencies, attracting more investors to the space.
With major U.S. regulatory agencies issuing detailed compliance guidelines for crypto custody, stablecoin reserves, and token disclosure, the industry is moving toward greater transparency and institutional integration.
Outlook
As of December 10, leading crypto assets on Gate Exchange are showing positive momentum, with Bitcoin trading at $92,658 and Ethereum at $3,319.
With U.S. banks now authorized to enter the crypto trading arena, the convergence of traditional finance and digital assets is accelerating. This regulatory-driven transformation is redefining the boundaries of the financial system, offering everyday investors unprecedented opportunities for asset allocation.
As Wall Street capital begins to flow steadily into the crypto market through the banking system, the foundation for the next bull run may already be quietly laid out in regulatory filings.
