The U.S. Office of the Comptroller of the Currency (OCC) has issued new guidance clarifying that national banks may hold crypto-assets on their balance sheets for the limited purpose of paying blockchain network fees, marking another formal step in integrating crypto into regulated banking infrastructure.
In Interpretive Letter 1186, released on Nov. 18, the OCC confirmed that a national bank may
“Pay network fees… on blockchain networks to facilitate otherwise permissible activities” and may “hold, as principal, amounts of crypto-assets… necessary to pay network fees for which the bank anticipates a reasonably foreseeable need.”
The agency added that banks may also hold crypto-assets “necessary for testing otherwise permissible crypto-asset-related platforms.”
The clarification formally greenlights that banks can keep small amounts of native tokens like Ethereum (ETH) to pay gas fees on behalf of customers or to run blockchain-based services, provided the activity is conducted in a “safe and sound manner and in compliance with applicable law.”
Part of a broader framework for bank-crypto services
The latest decision builds directly on the OCC’s earlier Interpretive Letter 1184 (May 2025), which confirmed that national banks may provide crypto custody and execution services, including through sub-custodians, and may outsource these functions subject to risk controls.
In the letter, the OCC reiterated that banks can “buy and sell assets held in custody at the customer’s direction” and participate in crypto-asset activities permitted in prior guidance dating back to 2020.
Taken together, the OCC’s 2025 interpretive letters now outline a full operational stack:
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Custody
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Trade execution
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Stablecoin reserves
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Node operation
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Network-fee management
Why this matters for banks entering digital-asset rails
Allowing banks to hold crypto for gas fees removes a practical bottleneck for institutions building blockchain-based settlement, tokenization, or custody products. Without native tokens on hand, basic functions, like transferring customer assets, settling trades on-chain, or testing DLT systems, would be impossible.
Bloomberg Law noted that the OCC’s ruling effectively lets banks “hold crypto to enable the payment of blockchain network fees – as long as these are incurred to facilitate permissible activities.”
Institutional adoption pressure increases
The decision also aligns with comments from major industry figures seeking regulatory clarity.
Brian Armstrong, CEO of Coinbase, told U.S. lawmakers in October that enabling banks to handle operational crypto would “allow traditional financial institutions to finally interface directly with the on-chain economy.”
Cathie Wood of ARK Invest argued in her 2025 “Big Ideas” report that traditional financial infrastructure now represents “the plumbing for mass adoption.”
Another strong voice in this debate, Strategy’s Michael Saylor, has long argued that Bitcoin’s institutional adoption is unavoidable.
In a May 2023 interview with Kitco News, Saylor said it is “inevitable” that banks, corporations, governments, and non-profits will need Bitcoin, suggesting that institutional Bitcoin adoption is not a question of “if” but “when.”
Related: Michael Saylor denies dumping Bitcoin despite Strategy stock meltdown