Digital asset custody has become the entry point of choice for US banks moving into crypto. Since 2025, the Office of the Comptroller of the Currency has issued a run of interpretive letters confirming that national banks can hold crypto-assets for customers, outsource execution to third parties and, most recently, operate without a state money-transmitter licence. Custody, not trading, is where the largest US banks are choosing to compete first.
A regulatory green light built letter by letter
The foundation dates back to July 2020, when the OCC’s Interpretive Letter 1170 confirmed that national banks could hold the cryptographic keys behind a customer’s crypto-assets, the same safekeeping role banks already perform for securities. What has changed since is the range of activity sitting alongside that safekeeping.
In May 2025, Interpretive Letter 1184 confirmed that banks can buy and sell crypto-assets held in custody at a customer’s direction, and can outsource custody and execution to third parties provided they manage that third-party risk properly. Two more letters followed before the year was out: Letter 1186 in November, allowing banks to hold small crypto balances as principal to pay blockchain network fees, and Letter 1188 in December, permitting riskless principal transactions on a customer’s behalf. In June 2026, Interpretive Letter 1192 went further again, ruling that a national bank’s federal charter pre-empts state money-transmitter licensing rules for a bank engaged in digital-asset custody and execution.
Each letter narrows the same question: what counts as the business of banking when the asset is a blockchain-based token rather than a security or a dollar. The OCC’s answer, letter after letter, is that custody counts.
The charter wave follows the same logic
Chartering decisions have moved in step with the interpretive letters. On 12 December 2025, the OCC conditionally approved five new national trust bank charters for digital-asset entities: Ripple National Trust Bank, BitGo Bank & Trust NA, Fidelity Digital Assets NA, Paxos Trust Company NA and First National Digital Currency Bank. Each is restricted to trust-company functions, meaning custody, safekeeping, staking, fiduciary services and, subject to separate written approval, GENIUS Act stablecoin issuance, rather than deposit-taking or lending. The conditions attached, including minimum capital and 180 days of liquid operating expenses held in reserve, treat these as custody-and-safekeeping banks first.
Digital asset custody as the low-risk entry point
BNY was first among the large incumbent banks. Its Digital Asset Custody platform went live in the US in October 2022, and in August 2026 the bank added crypto staking to that same platform, extending a service it has run for four years rather than opening a separate trading operation. Citi and State Street are following the same approach on a shorter timeline. Citi’s Custody+ announcement states that the bank expects to go live with digital asset custody later in 2026, starting with bitcoin, built on its existing digital asset architecture so that crypto and traditional custody sit inside one client experience. State Street is building its platform on Taurus’s PROTECT infrastructure, covering storage, staking and asset servicing.
The pattern holds because custody carries a different risk profile to trading. A bank that safekeeps an asset and charges a fee for it is not taking that asset onto its own balance sheet or betting on its price. That distinction matters to a prudential regulator, and it is why every OCC letter since 1170 has been framed around safekeeping, execution at a customer’s direction or minimal balances needed to run the service, not proprietary crypto trading.
Stablecoin reserves are pulling custody in behind them
The GENIUS Act stablecoin regime is doing some of the work too. US Bank was selected in October 2025 to hold the reserves backing Anchorage Digital Bank’s payment stablecoins, a mandate built on US Bank’s existing global custody business rather than any new stablecoin-issuing licence of its own. Anchorage Digital Bank is the only crypto-native institution to hold a national trust bank charter from the OCC, and its stablecoins are structured to meet the Act’s reserve and Bank Secrecy Act requirements. For a custodian bank, backing that structure extends a service it already sells to asset managers and corporations; issuing a stablecoin itself does not.
That reserve-custody role is likely to widen as more issuers look for a bank counterparty to satisfy GENIUS Act requirements. Fintechly has covered the same infrastructure-over-issuance logic in Nium’s acquisition of stablecoin infrastructure provider Cypher, where a payments company bought its way into stablecoin plumbing rather than launching a coin of its own.
Custody’s role in stablecoin infrastructure is set to grow further as banks decide whether to become issuers themselves rather than reserve custodians. Analysis from Wolters Kluwer describes wallet and custody capabilities as a foundational competency for any bank operating as a Permitted Payment Stablecoin Issuer under the Act, since that status requires supporting continuous issuance, redemption and settlement without exposing reserve assets to operational risk. The OCC’s own proposed rulebook for issuers, a 350-page proposal published on 25 February 2026, is still open to comment, which leaves custody as the part of the stablecoin stack banks can build now with a settled legal basis, ahead of the issuer rules themselves.
Specialist custodians and the crypto ETF connection
Traditional banks are not alone in this market. Anchorage Digital Bank and BitGo already custody assets for several spot crypto ETF issuers, including 21Shares’ US products, and BitGo reported more than $100 billion in assets under custody in 2025. Their presence sets the bar new entrants are being measured against: institutional clients already trust specialist custodians with billions in ETF collateral, so a bank’s custody offering has to match that record on security and operational resilience, not balance-sheet size alone.
For banks weighing where to compete in digital assets, the calculus looks settled for now. Custody is cleared in detail by the OCC, it fits inside an existing licensed business line, and it does not require holding crypto risk on the balance sheet. A fuller list of active crypto custody and infrastructure providers is on Fintechly’s crypto sector directory.
