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The landscape for US banks engaging in crypto and stablecoin custody has significantly changed in early 2025, moving from a highly restrictive environment to one where it’s explicitly permissible, provided robust risk management is in place. This shift is largely due to new guidance from the Office of the Comptroller of the Currency (OCC), the Federal Reserve, and the Federal Deposit Insurance Corporation (FDIC).
Here’s a breakdown of which types of banks are now positioned to custody crypto and stablecoins, and some of the major players that are either already involved or are expected to expand their offerings:
Who Can Custody Crypto and Stablecoins Now (Based on 2025 Regulatory Guidance):
* National Banks and Federal Savings Associations (regulated by the OCC): The OCC has repeatedly affirmed and clarified that these institutions may provide cryptocurrency custody and execution services. This includes both fiduciary and non-fiduciary capacities.
* Key OCC Actions in 2025:
* Interpretive Letter 1184 (May 7, 2025): Confirmed that OCC-regulated institutions may buy and sell custodied crypto assets at customers’ direction and can outsource crypto-asset activities (like custody and execution) to third parties, subject to appropriate third-party risk management. This letter reinforces earlier guidance (like IL 1170 and IL 1183).
* Interpretive Letter 1183 (March 7, 2025): Reaffirmed that crypto-asset custody, certain stablecoin activities, and participation in independent node verification networks (distributed ledgers) are permissible.
* Implication: These banks no longer need to obtain specific “no-objection” from the OCC before offering these services; instead, they are monitored through the normal supervisory process, with a strong emphasis on risk management, cybersecurity, and AML/CFT compliance.
* State-Chartered Banks (regulated by the FDIC and/or Federal Reserve for state member banks):
* Both the FDIC (March 28, 2025) and the Federal Reserve (April 24, 2025) have rescinded prior restrictive guidance that created hurdles for banks engaging in crypto activities.
* They now allow supervised banks to engage in crypto-related activities (including custody and stablecoin activities) without prior notice or approval, as long as they can adequately manage the associated risks in a safe and sound manner.
* Implication: This levels the playing field, allowing a broader range of US banks to enter the digital asset space.
Major Banks and Financial Institutions Already Active or Expected to Expand:
Given the improved regulatory clarity and the increasing institutional demand for digital asset services, several major players are well-positioned or already active:
* BNY Mellon: Has been a significant player in the crypto custody space among traditional banks. They launched their digital asset custody platform in late 2022 and are likely to expand their offerings given the favorable regulatory environment.
* Fidelity Digital Assets: While not a traditional commercial bank, Fidelity has been a pioneer in offering institutional crypto custody and trading services. Their established presence positions them strongly.
* State Street: Another major institutional custodian, State Street has also been exploring and investing in digital asset capabilities, including custody solutions. They are a strong candidate to expand their offerings.
* JPMorgan Chase: While initially cautious, JPMorgan has been actively involved in blockchain technology (e.g., JPM Coin for wholesale payments). They are likely to continue exploring and potentially expanding their custody capabilities, especially for institutional clients.
* Goldman Sachs: Has been increasing its involvement in digital assets, including trading and potentially custody for institutional clients.
* Trust Companies and Specialized Custodians: Many traditional trust companies, and even some smaller, crypto-friendly banks or regulated digital asset custodians, will continue to play a crucial role. The new OCC guidance explicitly allows banks to use sub-custodians, which benefits these specialized firms.
* Regional Banks and Others: With the removal of supervisory “non-objection” requirements, more regional banks and state-chartered institutions may now feel comfortable entering the crypto custody and stablecoin space, especially for their corporate and institutional clients.
What Does “Custody” Mean in This Context?
For banks, crypto custody typically involves:
* Safekeeping of private keys: This can be done via cold storage (offline) or hot storage (online, but with robust security protocols).
* Fiduciary and Non-Fiduciary Services: Banks can hold assets as fiduciaries (e.g., for trusts or funds) or in a non-fiduciary capacity (simply safeguarding assets for a fee).
* Execution Services: The OCC’s latest guidance also clarifies that banks can buy and sell custodied crypto assets at their customers’ direction.
* Integration with Traditional Banking: The ultimate goal is often to integrate digital asset services seamlessly with traditional banking products, allowing clients to manage both fiat and crypto assets within a single, regulated environment.
The general trend in 2025 indicates a significant move towards broader integration of crypto and stablecoins into the traditional US banking system, with more and more regulated financial institutions expected to offer these services.

Video courtesy of First Bank of Nigeria

Video courtesy of First Bank of Nigeria