TLDR
In the United States, the Office of the Comptroller of the Currency, the Federal Reserve Board, and the FDIC have allowed banks to offer crypto custody under supervised rules per recent guidance from the agencies US federal banking regulators.
- The OCC explicitly affirmed national banks may provide crypto custody (Interpretive Letter 1170) per a recent overview OCC letter 1170.
- The FDIC rescinded prior pre?approval requirements for bank crypto activities, including custody, if risks are managed FDIC policy change.
- Hong Kongs SFC and FSTB are moving to license crypto custodians, enabling bank?affiliated custody in a regulated framework Hong Kong licensing.
Deep Dive
1. US Banking Agencies
The OCC, Federal Reserve Board, and FDIC have clarified that banks can engage in crypto?asset activities, including custody, provided they operate in a safe and sound manner and under existing laws US federal banking regulators.
- The FDICs December update removed blanket pre?approval for crypto activities, aligning with the Fed and OCC stance that risk controls must be in place FDIC policy change.
- The Federal Reserve also withdrew a 2023 policy that discouraged novel crypto activities for certain banks, moving toward case?by?case oversight Fed rescission.
US banks can offer custody if they meet supervisory expectations (risk management, controls), unlocking institutional demand while staying within traditional safeguards.
2. OCC Custody Clarification
The OCC previously affirmed that national banks may provide cryptocurrency custody services for customers, including safekeeping of cryptographic keys (Interpretive Letter 1170), and has since clarified other routes for bank crypto brokerage and execution OCC letter 1170.
- Recent guidance also confirmed banks can facilitate riskless principal crypto trades (brokering without holding inventory or market risk), tightening operational guardrails while enabling participation OCC brokering framework.
The OCCs approach allows custody and execution in tightly supervised models, favoring well?controlled, scalable services over speculative activity.
3. Hong Kong Framework
Hong Kong is expanding its digital?asset regime to require licensing for virtual?asset dealers and custodians, closing gaps beyond exchange platforms and formalizing compliant custody offerings Hong Kong licensing.
- Regulators highlight secure private?key handling and client?asset protection; consultative steps aim at a comprehensive, institutional?grade framework by 2026 %%CKPROTECTED0%%.
Bank?affiliated custody in Hong Kong should operate through SFC licensing, reinforcing security, AML, and governance standards as the market institutionalizes.
Conclusion
Banks can offer crypto custody where regulators have clarified supervised pathwaysmost notably via the OCC, Federal Reserve, and FDIC in the USwhile Hong Kong is formalizing licensing for custodians. The common thread is permission with safeguards: risk control, secure key management, and compliance, which could increase institutional participation without relaxing prudential standards.
