Office of the Comptroller of the Currency (OCC)

On July 22, 2020, the Office of the Comptroller of the Currency published an interpretive letter clarifying the authority of national banks to provide cryptocurrency custody services for customers. This latest guidance is just one of many recent developments coming out of the OCC focused on modernizing the regulatory framework at the national level. 
Continue Reading OCC Releases Guidance on the Authority of National Banks to Provide Cryptocurrency Custody Services

Last week, the Office of the Comptroller of Currency, the primary federal regulator of national banks, issued an advanced notice of proposed rulemaking relating to the regulation of digital activities in banking, and in particular their activities involving cryptocurrency and distributed ledger technology.
Continue Reading OCC Seeks Comment on Cryptocurrency and Distributed Ledger Technology

On February 20, 2020, the federal Office of the Comptroller of the Currency (OCC) announced a Bank Secrecy Act enforcement action against a federal savings bank (Bank). This is one of the first, if not the first, public enforcement actions against a bank related to banking cryptocurrency-related operations. Banks that currently provide banking services to cryptocurrency-related companies, or are considering providing banking services to such companies in the future, should carefully review this enforcement action and consider where the quality of the bank’s AML compliance program is commensurate with these high-risk customers.
Continue Reading OCC Announces Crypto Enforcement Action