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Cryptocurrency Banking Sector Risk Management

McGuireWoods LLP

Federal Banking Regulatory Agencies Issue Guidance on Crypto-Asset Safekeeping

McGuireWoods LLP on

The global crypto-asset market cap has increased from approximately $2.3 trillion on election day, November 5, 2024, to approximately $3.9 trillion today, some eight months later. That rise in demand has been accompanied by a...more

BakerHostetler

Weekly Blockchain Blog - July 2025 #3

BakerHostetler on

According to a recent press release, a major U.S. bank has entered into a strategic partnership with the largest U.S. cryptocurrency exchange platform. This collaboration reportedly aims to expand access to secure digital...more

Paul Hastings LLP

Banking Regulators Clarify Crypto Custody Expectations, Congress Advances Landmark Digital Asset Legislation and Senate Releases...

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In a pivotal week for digital asset policy, federal banking regulators issued long-awaited guidance outlining risk-management expectations for crypto-asset safekeeping activities. The OCC, Federal Reserve and FDIC released a...more

DLA Piper

Stablecoins and the Genius Act: What You Need to Know

DLA Piper on

On July 17, 2025, the US Congress passed the Guiding and Establishing National Innovation for US Stablecoins Act (Genius Act or Act) by 308–122 vote, a landmark piece of legislation establishing the first federal regulatory...more

Morrison & Foerster LLP

Crypto-Asset Safekeeping: What’s Involved If You’re a Bank (or if You Want to Be One)

On July 14, 2025, the federal banking agencies issued a joint statement to clarify regulatory expectations for banking organizations that provide or are considering providing safekeeping for crypto-assets (“Joint Statement”)....more

Latham & Watkins LLP

Banking Agencies Issue Joint Statement on Risk-Management Considerations for Cryptoasset Safekeeping

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Banking organizations safekeeping digital assets for customers must do so in a safe and sound manner and in compliance with applicable laws and regulations....more

Sheppard Mullin Richter & Hampton LLP

Federal Banking Regulators Issue Joint Guidance on Crypto-Asset Safekeeping

On July 14, the OCC, Federal Reserve, and FDIC announced the release of a joint statement clarifying how existing laws and regulations apply to crypto-asset safekeeping services offered by banking organizations. The statement...more

Orrick, Herrington & Sutcliffe LLP

Prudential regulators release statement on cryptocurrency safekeeping

On July 14, the OCC, the Fed, and the FDIC issued a joint statement addressing how existing laws, regulations and governing principles apply to banks which provide or are considering providing safekeeping for...more

Troutman Pepper Locke

Federal Agencies Release Guidance on Crypto-Asset Safekeeping for Banks

Troutman Pepper Locke on

On July 14, the Office of the Comptroller of the Currency (OCC), the Board of Governors of the Federal Reserve System (the Board), and the Federal Deposit Insurance Corporation (FDIC) jointly issued a statement addressing the...more

American Conference Institute (ACI)

[Event] 24th Annual Canadian Forum on Anti-Money Laundering and Financial Crime - June 25th - 26th, Toronto, ON, Canada

Canada’s financial sector is facing unprecedented scrutiny, rising enforcement, and evolving compliance risks – are you ready? Join top regulators and industry leaders at CI's 24th Annual Canadian Forum on Anti-Money...more

Orrick, Herrington & Sutcliffe LLP

OCC clarifies crypto-asset activities in interpretive letter

On May 7, the OCC clarified permissible activities for national banks and federal savings associations regarding crypto-asset custody and execution services by publishing Interpretive Letter 1184. This letter confirmed...more

Latham & Watkins LLP

OCC Affirms Banks Can Engage in Crypto Custody and Execution Activities

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The federal banking agencies continue to open the channels for regulated entities to engage in digital asset activities. On May 7, 2025, the Office of the Comptroller of the Currency (OCC) published Interpretive Letter...more

Orrick, Herrington & Sutcliffe LLP

Senate committee seeks information on DOGE’s impact at FDIC

On April 24, four members of the U.S. Senate Committee on Banking, Housing, and Urban Affairs sent a letter to the FDIC requesting information regarding DOGE’s involvement at the FDIC. The senators are seeking information...more

Orrick, Herrington & Sutcliffe LLP

Treasury’s Bessent outlines vision for community banks

On April 9, the Secretary of the Treasury, Scott Bessent, delivered a speech outlining the Trump Administration’s financial policy goals of empowering community banks, moving away from prioritizing large financial...more

Smith Anderson

From “Debanking” to Deregulation: A Turning Point for Reputational Risk

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Federal banking regulators are rapidly rewriting the playbook. In the early months of the second Trump administration, sweeping shifts in policy and supervisory priorities are already taking shape. One of the most...more

Hogan Lovells

UK PRA Business Plan 2025/26: Priorities evolving towards increasing emphasis on competitiveness and growth

Hogan Lovells on

The PRA has published its Business Plan for 2025/26, setting out the workplan for each of its strategic priorities and strategy to advance its primary and secondary objectives. The PRA comments that, alongside its continual...more

Orrick, Herrington & Sutcliffe LLP

FDIC no longer requires notification of crypto-related activities

On March 28, the FDIC announced new guidance allowing FDIC-supervised institutions to engage in permissible crypto-related activities without prior approval. This update, outlined in FIL-7-2025, rescinded the previous...more

Latham & Watkins LLP

FDIC Removes Roadblocks to Crypto Activities in the Banking Sector

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New FDIC guidance permits crypto activities by supervised institutions without prior approval, emphasizing risk management and compliance with applicable laws and regulations....more

Sheppard Mullin Richter & Hampton LLP

FDIC Aims to Eliminate Reputational Risk from Supervision

On March 24, acting FDIC Chairman Travis Hill informed Congress that the agency is preparing to eliminate the use of “reputation risk” as a basis for supervisory criticism. In a letter to Rep. Dan Meuser (R-Pa.), Hill...more

Sheppard Mullin Richter & Hampton LLP

OCC Signals Shift on Crypto and Debanking Under Acting Comptroller Hood 

On March 18, Acting Comptroller of the Currency Rodney Hood reiterated the OCC’s commitment to ensuring fair access to banking services, including for cryptocurrency firms. Speaking at a retail banking industry conference,...more

Ballard Spahr LLP

Crypto Clarity: OCC’s New Guidelines Pave the Way for Banking Innovation

Ballard Spahr LLP on

On March 7, 2025, the Office of the Comptroller of the Currency (“OCC”) released Interpretive Letter 1183, marking a pivotal change in regulatory guidance for national banks and federal savings associations engaging in...more

Wilson Sonsini Goodrich & Rosati

A Crypto-Friendly Pivot in Bank Supervision: Three Practical Action Items for Innovators

A federal banking agency, the Office of the Comptroller of the Currency (OCC), has smoothed the way for national banks and federal savings associations to engage in crypto-related activities with the issuance of Interpretive...more

Sheppard Mullin Richter & Hampton LLP

OCC Clarifies Banks’ Role in Cryptocurrency Activities

On March 7, the OCC issued Interpretive Letter 1183 and an accompanying statement affirming prior guidance regarding whether national banks and federal savings associations may engage in cryptocurrency-related activities,...more

Davis Wright Tremaine LLP

OCC Rescinds Required Supervisory "Non-Objection" Preclearance for Permissible Crypto-Related Activities

The OCC has reiterated that certain crypto-related activities—crypto-asset custody, distributed ledger, and stablecoin activities—previously determined to be permissible remain so. The OCC has also rescinded a Biden-era...more

Orrick, Herrington & Sutcliffe LLP

Congressional Research Service report highlights de-banking risks

On January 29, the Congressional Research Service (CRS) released a report on the challenges banks may face in providing services to certain individuals and businesses. The CRS’s report was based on the perception that an...more

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