Here’s what’s materially changed at the intersection of banking and Bitcoin in the last quarter:
🏦 OCC Deepens Operational Clarity for Bitcoin Banking
📜 OCC Interpretive Letter 1186 (November 2025)
The OCC clarified that national banks may hold limited amounts of crypto assets as principal when reasonably necessary to support permissible activities — such as paying network transaction fees tied to custody or settlement services.
This matters because it removes lingering ambiguity around whether banks could operationally interact with blockchain networks without tripping balance-sheet concerns.
Source: OCC
📜 OCC Interpretive Letter 1188 (December 2025)
The OCC further confirmed that banks may engage in “riskless principal” crypto transactions, acting as an intermediary between buyers and sellers without taking market risk — a familiar brokerage structure now explicitly permissible for crypto assets.
Taken together, these letters move crypto activity out of theory and into bank-grade execution models.
Source: OCC
🏛️ Federal Reserve Ends “Special” Crypto Supervision
In August 2025, the Federal Reserve announced it would sunset its Novel Activities Supervision Program, folding crypto-related oversight back into standard bank examination processes.
Translation: crypto exposure is no longer treated as a special category requiring bespoke scrutiny — a meaningful normalization for banks evaluating Bitcoin products.
Source: Federal Reserve
🪙 Stablecoins Enter a Federal Banking Framework
The GENIUS Act, passed in mid-2025, is now moving from statute to implementation. The law establishes a federal framework for payment stablecoins, explicitly including insured depository institutions as permitted issuers under defined reserve and compliance rules.
While not Bitcoin-specific, this is critical infrastructure: regulated stablecoin rails increasingly underpin Bitcoin settlement, custody funding flows, and treasury operations inside banks.
Source: U.S. Congress, Brookings Institution
🧾 Market Structure Legislation Continues to Advance
Since August, the Digital Asset Market Clarity Act (CLARITY Act) has remained active in Congress, with Senate counterparts refining jurisdictional definitions between the SEC, CFTC, and banking regulators.
Final form is still in flux, but momentum has shifted decisively toward statutory clarity rather than enforcement-by-ambiguity — a key prerequisite for bank-led Bitcoin services at scale.
Source: U.S. Congress, Coinpedia
🌍 Global Banks Keep Building Bitcoin Rails
Outside the U.S., regulated Bitcoin infrastructure continues to expand:
- Deutsche Börse’s Clearstream announced institutional crypto custody and settlement services, beginning with Bitcoin.
- European banks operating under MiCA continue to formalize custody and brokerage offerings, reinforcing Bitcoin’s place within regulated capital markets.
Source: Deutsche Börse, Legal Nodes
📌 Wrap-Up
Since our last edition, the amount of clarity and inertia in the space has been impressive.
- U.S. regulators are shifting from permission to precision, clarifying how banks can operate rather than whether they can.
- Bitcoin is being normalized inside supervisory frameworks, not siloed outside them.
- Stablecoin and custody infrastructure is converging, creating bank-native on-ramps to Bitcoin services.
- Global financial institutions are operationalizing Bitcoin, not just studying it.
The takeaway: Bitcoin banking is no longer a regulatory experiment — it’s a product roadmap discussion.
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