OCC Confirms Riskless Principal Transactions in Crypto Assets by Banks Are Permissible

On December 9, 2025, the OCC issued Interpretive Letter #1188 to confirm that national banks may engage in riskless principal crypto-asset transactions, including transactions in assets that are not securities. Riskless principal transactions occur when an intermediary purchases an asset from one counterparty for immediate resale to a second counterparty. Banks are generally permitted to engage in such transactions and the OCC does not view involvement of crypto assets in the transactions as…
By: Jones Day