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

> 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.

- URL: https://riadefi.com/regulation/2025-05-07-occ-interpretive-letter-1184-crypto-custody-execution/
- Posture: Guidance
- Authorities: Office of the Comptroller of the Currency
- Event date: 2025-05-07
- Version: 1, published 2026-08-07 (first published 2026-08-07)
- Advisor-relevant: yes

## 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.

## Sources

1. [Interpretive Letter 1184](https://www.occ.treas.gov/topics/charters-and-licensing/interpretations-and-decisions/2025/int1184.pdf) · Office of the Comptroller of the Currency · 2025-05-07


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Published by Ketju Research on RIADeFi (https://riadefi.com). Educational research for financial professionals; not investment, legal, tax, or compliance advice.