United States of America: Office of the Comptroller of the Currency released Interpretive Letter 1186 on Authority of National Banks to Hold Crypto-Assets as Principal and Pay Crypto-Asset Network Fees as Incidental to a Permissible Banking Activity

On 18 November 2025, the Office of the Comptroller of the Currency (OCC) released Interpretive Letter 1186. The letter confirms that a national bank may pay network fees on blockchain networks as an activity incidental to banking. It also allows a bank to hold crypto-assets on its balance sheet, as principal, to cover network fees that it reasonably anticipates needing. The letter notes that these activities support other permissible crypto-related banking activities, including custody, stablecoin payments, and operating distributed ledger technology nodes. It also states that a national bank may hold crypto-assets to test crypto-asset platforms, whether developed internally or acquired from third parties. Interpretive Letter 1186 provides background on distributed ledger technology, network fees, testing requirements, and the bank’s proposed activities. The OCC concluded that these activities are convenient or useful to permissible banking operations and consistent with 12 U.S.C. 24(Seventh) and 12 C.F.R. 7.1000.