U.S. OCC Defines How Banks Can Legally Manage Crypto for Gas Fees

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Interpretive Letter No. 1186 Gives Banks the Green Light to Hold Crypto for Operational Needs

The U.S. Office of the Comptroller of the Currency (OCC) has issued new clarity on how national banks can legally manage cryptocurrency holdings for blockchain-related operations.
In Interpretive Letter No. 1186, released Tuesday, the agency confirmed that banks may keep digital assets on their balance sheets if those assets are reasonably necessary for their day-to-day operations—particularly for paying blockchain “gas fees."

Gas fees are the mandatory costs paid in a blockchain’s native token to process transactions. As banks expand into blockchain settlement, tokenized payments, and custody services, the ability to store limited crypto amounts has become essential.

The new directive removes years of uncertainty and explicitly authorizes such operational holdings.

Why This Matters

For banks, interacting with blockchain networks often requires paying network fees directly. However, previous regulatory ambiguity made holding crypto—even for this functional purpose—difficult to justify.

Interpretive Letter No. 1186 now erases that ambiguity.

Key Permissions Granted:

  • Banks may hold crypto assets as principal if they are needed to pay network fees for activities the bank is already allowed to perform.

  • Such activities include those explicitly allowed under the Guiding and Establishing National Innovation for U.S. Stablecoins (GENIUS) Act, where banks may need to pay gas fees on behalf of customers or as part of their custody operations.

  • Banks may anticipate reasonably foreseeable needs and maintain the crypto necessary to support those functions.

In the OCC’s words, maintaining these assets is “permissible for the bank.”

A Turning Point for U.S. Banking Regulation

This move reflects a broader regulatory shift. Several federal agencies—including the Federal Reserve, FDIC, and the Treasury Department—are currently drafting full stablecoin regulatory frameworks under the new GENIUS Act. While those formal rules are still pending, the OCC’s guidance fills an important gap by enabling operational preparedness.

The clarification is also part of a broader reversal in attitudes toward digital assets within U.S. banking policy.

A Pro-Crypto Shift Under the Trump Administration

The OCC’s stance has noticeably shifted alongside the pro-innovation, pro-crypto posture of President Donald Trump’s administration. The agency is now led by Comptroller Jonathan Gould, a Trump appointee confirmed by the Senate in July.

Under this leadership, the OCC has moved away from earlier caution and is now laying the regulatory groundwork for banks to engage responsibly with blockchain technology.

Industry Implications

The guidance is expected to accelerate bank involvement in:

  • Stablecoin issuance and settlement

  • Blockchain-based payment rails

  • Tokenized asset custody

  • On-chain transaction processing

For banks exploring tokenization or digital settlement systems, the ability to hold gas-fee tokens is a foundational requirement. This letter ensures they can do so confidently within federal law.

Looking Ahead

While Interpretive Letter No. 1186 stops short of granting banks broad latitude to trade or speculate in crypto, it marks a significant milestone in aligning traditional finance with digital asset infrastructure.

As the U.S. works toward comprehensive stablecoin oversight, the OCC has made it clear:
Blockchain operations are now firmly within the permissible activities of regulated national banks—gas fees included.

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