The U.S. Office of the Comptroller of the Currency, or OCC, has taken another step toward integrating digital assets into the traditional banking system. In Interpretive Letter No. 1186, the regulator said national banks may hold cryptocurrency on their balance sheets when that crypto is needed to pay blockchain network fees. For banks exploring digital asset services, this is a practical and important clarification because blockchain networks generally require native tokens to process transactions.
The guidance also extends beyond fee payments alone. According to the OCC, banks may maintain crypto balances for the purpose of testing internal crypto platforms or third-party crypto infrastructure. That matters because a bank that wants to offer blockchain-based services often needs to interact with live networks, simulate workflows, and validate internal controls. In many cases, none of that can happen without access to the native token required by the relevant blockchain.
The OCC’s reasoning is straightforward: paying network fees is a necessary part of doing business on blockchain networks, and holding crypto for that limited purpose is permissible when it supports otherwise lawful banking activity. The agency also suggested that allowing banks to hold small working balances of crypto could reduce dependence on outside providers and lower operational risk. Instead of relying entirely on third parties to source tokens every time a transaction must be sent, a bank can manage that process internally within a supervised framework.
Why the OCC treats this as an incidental banking activity
A central phrase in the letter is that these activities are “incidental to the business of banking.” In U.S. banking law, that is a meaningful regulatory concept. It means an activity can be allowed not because banks are free to speculate in it, but because the activity is connected to core banking services and helps the bank serve customers or operate efficiently. The OCC is not redefining banks as crypto investment firms. It is recognizing that some level of token holding may be operationally necessary in a blockchain-based environment.
To support that view, the OCC draws parallels with historical banking practices. Banks have long held foreign currency, banknotes, or shares and interests tied to payment systems in order to facilitate transactions. Those assets were not held as ends in themselves, but as tools that made financial services possible. The OCC’s message is that crypto, in this context, can be understood in the same way: not as a broad endorsement of digital asset exposure, but as a modern transactional instrument needed to support certain services.
This distinction is crucial. The guidance does not suggest that banks should carry large proprietary crypto positions or use their balance sheets to make directional bets on token prices. Instead, the OCC says banks may hold the amount of crypto they reasonably anticipate needing. That could include tokens used to pay gas fees for custody transfers, wallet movements, settlement activity, or transactions carried out on behalf of customers. The emphasis is on necessity, reasonableness, and lawful support of banking operations.
Scope of the permission and the risk controls banks must follow
Even though the OCC has become more open to crypto-related banking activity, the letter makes clear that risk management remains non-negotiable. Banks are expected to identify, monitor, and manage a range of risks tied to these activities. The list specifically includes operational risk, market risk, liquidity risk, cybersecurity risk, and legal risk. That reflects the reality that even a seemingly simple act, such as holding tokens for transaction fees, can involve wallet management, key security, transaction timing, reconciliation, vendor dependencies, and compliance recordkeeping.
The OCC also states that the amount of crypto held for these purposes should remain minimal relative to the bank’s capital. This condition reinforces the limited nature of the authorization. The point is not to let banks convert balance sheet capacity into broad digital asset exposure. Rather, it is to permit carefully bounded working inventories that help banks execute lawful services on blockchain networks without creating outsized financial risk.
In practical terms, the guidance is especially relevant for a few real-world use cases. One is crypto custody. If a bank safeguards customer digital assets and needs to move them on-chain, it may need access to native tokens in order to pay the required blockchain fees. Another is transaction facilitation, where a bank helps execute or settle a client-related blockchain transfer. In both scenarios, maintaining a small reserve of the relevant token can be more efficient than sourcing it externally each time a transaction is initiated.
The letter also acknowledges the need for testing environments and platform readiness. A bank building internal blockchain capabilities or evaluating a third-party crypto platform may need to perform live or near-live testing. Because blockchain systems are not free to use, those tests may require native tokens. By explicitly permitting this type of holding, the OCC reduces ambiguity around whether banks can maintain token balances for development and operational validation rather than for investment purposes.
Jonathan Gould and the OCC’s broader shift on crypto
The timing of the letter is notable because it comes under the leadership of Comptroller Jonathan Gould, a Trump appointee who was confirmed in July 2025. According to the source article, the OCC has become more crypto-friendly during his tenure. That does not mean the regulator has abandoned caution. Instead, the pattern suggests a policy approach that prefers supervised participation over blanket exclusion, especially where banks can demonstrate controls and remain within established legal limits.
Earlier OCC guidance had already signaled this direction. Prior interpretations allowed banks to act as nodes on blockchain networks, offer crypto custody services, and work with stablecoins. Each of those steps addressed a different layer of crypto-related banking activity: infrastructure participation, safekeeping of customer assets, and engagement with digital payment instruments. Interpretive Letter 1186 adds another operational piece by clarifying that banks may hold the tokens necessary to make those functions work in practice.
At the same time, the broader federal framework for stablecoin issuers is still evolving. The article notes that rules under the GENIUS Act are still being drafted. That means some of the biggest questions around dollar-backed digital payment instruments remain unresolved. Even so, the OCC’s latest move indicates that U.S. regulators are willing to let banks participate in parts of the crypto ecosystem in ways they consider safe and efficient, rather than waiting for every legislative detail to be finalized first.
What this means for adoption by banks and the crypto industry
As more banks evaluate digital asset strategies, this kind of guidance could accelerate adoption by removing a basic operational barrier. Many blockchain-based services sound feasible in theory, but they break down in practice if an institution cannot legally hold the token needed to pay transaction fees. By resolving that question, the OCC gives banks a clearer path to integrating blockchain activity into routine workflows such as custody operations, settlement functions, transfers, and technical testing.
The article also points to an earlier action from this year: Interpretive Letter 1184, which allowed national banks and federal savings associations to offer cryptocurrency custody and trading services. Under that earlier guidance, banks could buy and sell digital assets on behalf of customers, outsource crypto activities to third parties, and provide related support functions such as recordkeeping, tax reporting, and compliance services. Seen together, Letters 1184 and 1186 form part of a broader architecture for bank participation in crypto markets.
For the industry, the significance is not that U.S. banks will suddenly become aggressive crypto investors. The more important change is regulatory clarity. Financial institutions tend to move when the boundaries are explicit: what they may do, for what purpose, under what controls, and with what scale limitations. On those questions, the OCC has now provided a more concrete answer for fee-related token holdings, platform testing, customer support operations, and crypto-enabled banking infrastructure.
In that sense, the decision acts as a bridge between traditional finance and blockchain networks. It acknowledges that if banks are going to support digital assets in real workflows, they need permission to handle the operational tools that those workflows require. Native tokens for gas fees may be a small part of the overall crypto stack, but they are essential. By allowing banks to hold them within a narrow and supervised framework, the OCC has made blockchain participation more practical for regulated financial institutions in the United States.