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OCC confirms national banks may engage in ‘riskless principal’ digital assets transactions

December 12, 2025

On December 9, the OCC issued an interpretive letter, confirming that national banks may engage in “riskless principal” transactions involving digital assets as part of the business of banking. The OCC stated these transactions involve a bank acting as principal in a digital asset transaction with one customer while simultaneously entering into an offsetting transaction with another customer, serving as an intermediary and not holding digital assets in inventory. The OCC stated that this activity is the economic equivalent to a broker acting as agent. The letter distinguished between riskless principal transactions involving digital assets that are securities, which are already recognized as permissible for national banks, and those that are not securities. In conclusion, the OCC held that both types of transactions are permissible as part of the business of banking, provided they comply with existing laws and are conducted in a safe and sound manner.