April 26, 2021

OCC Says National Banks May Provide Custody Services for Cryptocurrency

By Stephen T. Middlebrook

On July 22, 2020, the Office of the Comptroller of the Currency (OCC) issued a letter stating that national banks and federal savings associations may provide cryptocurrency custody services for their customers. National banks have long served customers by safeguarding valuables in safe-deposit boxes and vaults, and this letter clarifies that such services may extend to digital assets. The OCC notes that cryptocurrency custody services may include holding the cryptographic keys associated with cryptocurrency as well as other services. A national bank that chooses to engage in these new activities should do so in a manner consistent with sound risk management practices and aligned with the bank’s overall business plans and strategies.

Stephen T. Middlebrook

Womble Bond Dickinson