Federal Reserve Requires Notification of Crypto-Asset-Related Activities

Federal Reserve Guidance Imposes Requirements Similar to Those Imposed by the OCC and FDIC Sullivan & Cromwell LLP - August 22, 2022

Following in the wake of recent supervisory guidance published by the Office of the Comptroller of the Currency (the “OCC”) and the Federal Deposit Insurance Corporation (the “FDIC”), on August 16, 2022, the Board of Governors of the Federal Reserve System (the “Federal Reserve”) issued a supervisory letter requiring all Federal Reserve-supervised banking organizations to notify their lead supervisory point of contact at the Federal Reserve prior to engaging in any crypto-asset-related activities, like the approach taken by the OCC and the FDIC. A supervised banking organization that is already engaged in such activities also must promptly notify Federal Reserve supervisory staff.