OCC Clarifies Bank Authority to Engage in Crypto Custody and Execution Services

• On May 7, the OCC issued Interpretive Letter 1184, which clarifies that national banks and federal savings associations (collectively, “banks”) may buy and sell assets held in custody at the custody customer’s direction in a manner consistent with the customer agreement and applicable law.
• Banks may also outsource bank-permissible crypto-asset activities, including custody and execution services, to third parties (including sub-custodians), subject to appropriate third-party risk management practices.

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