US banks have found a way to profit from crypto without the hassle—And this is the puzzle

In December, an important development in crypto regulation went largely unnoticed. The US Office of the Comptroller of the Currency issued a green light for national banks to facilitate cryptocurrency trades for their customers—without ever handling the actual coins themselves.

This is not just a technical approval. Interpretive Letter 1188 is a fundamental signal that settles a long-standing debate: the banking system in the US is officially open to crypto, but within specific boundaries.

Why this decision is important

The permission covers “riskless principal” transactions—where the bank buys from a customer and sells to another, without holding its own crypto assets. For those worried that the banking sector might struggle to join the crypto revolution, this is a significant help. It allows large financial institutions to offer customer-facing crypto trading and custody services using familiar banking infrastructure, without needing to operate new technology stacks or rely on external exchange partners.

But the real plot twist is the other announcement accompanying it. Comptroller Jonathan Gould openly stated that he sees no reason to treat digital assets differently from traditional banking activities. His stance directly impacts discussions around the national trust charter—a piece of infrastructure becoming a critical battleground in the crypto custody space.

Who controls the banking system, and why is this relevant

The OCC is the federal agency that issues charters to national banks and supervises their operations. As Comptroller, Gould is the chief executive with ultimate authority over who gets a banking license and what they are allowed to do. His perspective is deeply rooted in the financial ecosystem—he is a member of the Federal Deposit Insurance Corporation board and the Financial Stability Oversight Council.

The national trust charter is a specialized license for institutions focused solely on trust and fiduciary services—like a new type of banking license that does not confer full commercial bank status. Its strategy is clear: hold customer assets, manage settlement flows, but avoid the traditional deposit-taking burden and full regulatory weight. For crypto firms, this offers federal supervision, nationwide operational authority, and potential protection from higher holding-company requirements.

Why is this a puzzle? The traditional banking sector, including the Bank Policy Institute, worries that trust charters could become a backdoor route for crypto companies to operate like banks without the same oversight. The BPI has formally petitioned the OCC to restrict trust charter access specifically for crypto-focused applicants.

What exactly is the OCC allowing

Interpretive Letter 1188 clarifies three core things:

First, matched principal trading—where the bank buys from Customer A and immediately sells to Customer B. No inventory risk, just facilitation. For assets classified as securities, this operates under existing Section 24 of the National Bank Act. For other crypto assets, the letter applies a four-factor test and confirms that it still falls within the “business of banking.”

Second, custody services. OCC letters that previously established that stablecoin reserve holdings and basic crypto custody are valid banking functions remain valid. This provides a green light for national banks to hold digital asset reserves and offer safekeeping services.

Third, trust charter eligibility. Gould signaled that the OCC will not automatically reject crypto applicants for national trust charters, provided they meet the same standards—adequate capital, competent management, solid risk controls, and community benefit assessment.

What changes on a practical level

For large US banks that have avoided crypto, this is an opening. They can now build crypto brokerage operations with minimal balance sheet exposure. No need to join shady exchange partnerships or offshore operations.

For crypto exchanges, the opening is more significant. They can pursue a national trust charter and consolidate trading, fiat on-ramps, and on-chain custody under an OCC-supervised entity. This stack is more attractive to institutional clients requiring qualified custodian certification.

For stablecoin issuers, this shift is meaningful. Reserves can be held by an OCC-regulated trust bank on the federal balance sheet. Payment flows can be routed through Fed-connected correspondent networks. The issuer itself can remain outside the full banking framework.

Every step forward has a complex path

It does not mean automatic approval for every crypto company that applies. The OCC has broad discretion in the approval process. The BPI and other commenters have already filed detailed objections for specific applicants, citing weak consumer protection records, business model conflicts, or unclear ownership structures.

OCC examination teams have the final say. Gould’s headline speeches are just the foundation—the real filter is supervisory conditions, capital requirements, and operational stress tests demanded for each approval.

The global ripple effect

When US national banks start offering riskless principal routing for Bitcoin and Ethereum under OCC guidance, it will influence international banking strategies. Global financial institutions will calibrate their operations in London, Frankfurt, Singapore based on what works in the US.

If only a handful of crypto firms obtain a national trust charter and operate large custody and stablecoin reserves under federal supervision, it signals a structural shift away from the traditional offshore-exchange-plus-local-partner model.

The real message

The US banking system is not fully opening all doors. Rather, the OCC is beginning to tie specific crypto business activities to concrete regulatory frameworks: riskless principal trading, modern custody services, trust charters for fiduciary operations and reserves.

In an industry where regulatory uncertainty is the main business risk, this gradual clarification is as valuable as major legislation.

For crypto firms targeting US institutional capital, the roadmap is clearer now. For traditional banks hesitant to enter, they can see where the guardrails are. The speed of execution on both sides will reveal whether the OCC letter marks the start of a new era or just a temporary clarification.