The Office of the Comptroller of the Currency (OCC) has authorized US national banks to act as “riskless principal” intermediaries in crypto-asset trades, formalized in Interpretive Letter 1188 in December 2025.
Interpretive Letter 1188 permits banks to broker crypto trades across a range of tokens, including Bitcoin, Ethereum, XRP and Solana, while limiting their direct market exposure. Riskless principal is a trading arrangement in which an intermediary executes offsetting buy and sell orders on behalf of a client without maintaining net inventory.
The letter also clarifies that banks may provide custody services and hold digital assets for operational needs; a November 2025 clarification explicitly allowed banks to hold tokens to cover blockchain “gas fees.” This combination expands banks’ service set to include execution, custody and limited operational holdings, while aiming to preserve capital and liquidity safeguards by avoiding prolonged proprietary positions.
Regulatory context and market implications
The OCC action sits within a string of regulatory developments in 2025 that have relaxed earlier restrictions issued in 2022–2023, as the Federal Reserve and the FDIC retreated from several prior supervisory statements, creating room for banks to build crypto-facing services under supervisory frameworks. The Commodity Futures Trading Commission has been exploring a pathway since August 2025 to enable US customers to access offshore exchanges via the Foreign Board of Trade framework while supporting spot crypto trading on US futures platforms.
The SEC maintained enforcement activity—illustrated by the February 2025 suit involving a major exchange—yet approved the first staked-crypto exchange-traded fund in July 2025. Separately, a market participant secured a New York BitLicense in September 2025 to target institutional clients.
For traders and crypto treasuries, execution and custody options inside regulated banks could reduce counterparty and custody risk, while the permission to operate as a riskless principal lowers banks’ incentive to warehouse positions that elevate systemic exposure. However, the regulatory landscape remains fragmented: enforcement actions coexist with approvals and pilot frameworks, creating compliance and legal risk for institutions that move quickly. Firms will need heightened governance, counterparty limits, segregation practices and clear operational controls to align with supervisory expectations.
The interpretive letter marks a material shift from prohibition to controlled integration of crypto services within banking. Market participants should monitor how banks implement riskless principal workflows and how auxiliary rulemaking—particularly any CFTC action on FBOT pathways—affects cross-border execution and custody access.
