OCC confirms banks may execute and outsource crypto transactions tied to custody services

What changed

The OCC confirmed that national banks may provide customer-directed crypto-asset execution as an accommodation to custody services and may use sub-custodians and other third parties for permissible activities. Banks remain responsible for risk management, legal compliance, and safe-and-sound execution.

Who it affects

• National banks providing crypto custody
• Advisers selecting custody and execution arrangements for clients

What is still open

• Which bank service models and asset lists will be offered
• Allocation of execution, sub-custody, insolvency, and technology risks by contract

What it means for an advisor

• Diligence custody and execution as separate functions even when bundled by a bank
• Review routing, pricing, conflicts, sub-custodian, asset-control, and incident-response terms

Previous interpretation

Earlier OCC letters confirmed custody authority but left more uncertainty around ancillary execution and outsourcing models.