OCC Clarifies Banks' Ability to Hold Crypto for Network Gas Fees
On November 18, 2025, the Office of the Comptroller of the Currency (OCC) issued interpretive letter No. 1186, providing clarity on how national banks can handle blockchain network gas fees. The guidance explicitly allows banks to hold cryptocurrency assets on their balance sheets to cover anticipated and reasonably foreseeable network fees as part of their operations.
According to the letter, banks may act as paying agents for customers or as custodians for such crypto assets. This action is expressly permitted under the Guiding and Establishing National Innovation for U.S. Stablecoins Act. The OCC's move signals a more crypto-friendly stance, reversing previous hesitations regarding banks' involvement with digital assets.
The OCC is currently led by Comptroller Jonathan Gould, a Trump appointee confirmed by the Senate in July 2025. While other regulators including the Federal Reserve, FDIC, and Treasury are developing regulations for stablecoins under the GENIUS Act, those rules are not yet in effect. The OCC's interpretive letter provides early regulatory clarity for banks engaging with blockchain gas fees in the evolving crypto landscape.
