OCC Confirms U.S. Banks Can Act as Intermediaries for Crypto Trading via Riskless Principal Model
The Office of the Comptroller of the Currency (OCC), the primary regulator for national banks in the U.S., has issued a major clarification confirming that national banks are permitted to act as intermediaries for customer crypto asset transactions. The guidance, released on December 9, 2025, in Interpretive Letter 1188, specifically permits banks to engage in “riskless principal” crypto-asset transactions as part of the established “business of banking.” This decision marks a significant step in the regulatory trend to integrate digital assets into the traditional U.S. banking sector and is expected to accelerate regulated institutional participation in the crypto market.
The Mechanics of Riskless Principal Transactions
The OCC’s letter confirms that national banks can now offer crypto services in a manner legally and economically equivalent to traditional brokerage activities for securities. A riskless principal transaction involves a bank acting as an intermediary between two customers: the bank simultaneously purchases the crypto asset from one counterparty while entering into an offsetting transaction to immediately retrade the asset to another customer. Crucially, the bank serves as a broker acting as an agent and does not hold the crypto assets in inventory on its balance sheet, except for brief periods during the settlement process or in the event of a settlement failure.
This structure is described as “riskless” because the bank neutralizes its market risk through these near-instantaneous offsetting trades. The OCC determined that this activity falls within the established power of national banks under the National Bank Act, as it logically extends their traditional function as financial intermediaries. The ability to act as a regulated broker is a key service demanded by high-net-worth individuals and corporate clients viewking secure, compliant pathways to access the volatile digital asset market.
Driving Institutional Demand and Regulatory Clarity
The new guidance directly addresses the pent-up demand from U.S. banks viewking regulatory clarity to offer crypto services. By giving the green light for this low-risk intermediary role, the OCC is effectively ushering in a new wave of institutional adoption. Banks, which are subject to much stricter regulation than most crypto platforms, are expected to bring enhanced consumer protection and robust Anti-Money Laundering (AML) and Know Your Customer (KYC) controls to the trading process. This move is aligned with the OCC’s broader policy of technology-neutral regulation, which encourages banks to embrace new products without prohibiting innovation just because the underlying technology is new.
The guidance follows the recent public launch of direct BTC trading by PNC Bank, powered by Coinbase, which exemplified the type of institutional adoption the OCC is now formally endorsing. As with any permissible activity, the OCC mandates that banks conducting riskless principal crypto-asset transactions must do so in a secure and sound manner and in compliance with all applicable law, confirming that the OCC will examine these activities as part of its ongoing supervisory process.
