The Office of the Comptroller of the Currency issued Interpretive Letter 1186 on November 18, confirming that national banks may pay blockchain network fees for activities already allowed under banking rules. The letter also confirms that banks can hold limited amounts of crypto-assets on their balance sheets when those assets are needed to perform these […]The Office of the Comptroller of the Currency issued Interpretive Letter 1186 on November 18, confirming that national banks may pay blockchain network fees for activities already allowed under banking rules. The letter also confirms that banks can hold limited amounts of crypto-assets on their balance sheets when those assets are needed to perform these […]

Crypto Move: OCC Delivers High-Impact Clarity on Bank Handling of Network Fees

2025/11/19 15:00
3 min read
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  1. The OCC confirmed that national banks can pay blockchain network fees and hold the crypto needed for those payments.
  2. The ruling clarifies how banks can handle small crypto balances for testing and daily operations.
  3. Analysts such as Mark Hensley say the guidance removes long-standing uncertainty for regulated banks.

The Office of the Comptroller of the Currency issued Interpretive Letter 1186 on November 18, confirming that national banks may pay blockchain network fees for activities already allowed under banking rules.

The letter also confirms that banks can hold limited amounts of crypto-assets on their balance sheets when those assets are needed to perform these tasks. This includes small amounts of native tokens required to process transactions or operate platforms that the banks already use for customer services.

The OCC explained that blockchain networks often require network fees, commonly referred to as gas fees, to move assets or interact with smart contracts. Without these fees, transactions cannot be finalized.

The agency said that holding the crypto used for these fees is permitted when it directly supports a bank’s existing services. Market analyst Mark Hensley noted that the decision settles several years of uncertainty for traditional institutions experimenting with digital asset infrastructure.

Banks Receive Clarity on Testing Crypto Platforms

Internal testing is also touched upon. OCC reported that when banks are testing crypto-assets related to custody tools, settlement systems, or other services, they can hold small amounts of crypto-assets. These practices are regarded as responsible product development.

Testing usually includes trial testing, settlement testing, wallet testing, and control testing. Without access to the necessary native tokens, the banks would need to use third-party providers, which can create operational and security risks.

The OCC emphasized that with minimal balances in crypto deposited by banks, such risks decrease and promote appropriate internal testing of new services before releasing them.

Analyst Rebecca Moore indicated this explanation assists the banks in modernizing their systems without crossing the regulatory lines.

Risk Management Remains a Core Requirement

Although the letter provides a wider space to the banks, it also emphasizes high levels of risk management. The OCC stated that banks should deal with operational, cybersecurity, liquidity, market, and compliance risks.

The amounts of crypto owned by individuals will have to be minimal in connection with the capital of a bank, and such assets should not be traded or speculated on, but be utilized with a strictly functional purpose.

The ruling is consistent with the existing cases, such as in the past letters that permitted the national banks to offer crypto custody, operate with stablecoins, and operate nodes on blockchain networks.

By providing an explanation of how network charges are managed, the OCC would gain a level of success in assisting banks to provide more efficient and quicker services as blockchain technology gains more applicability in payment systems and settlement services.

Also Read: Brazil Plans to Tax Crypto Transactions for Cross-Border Payments

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