Home
US Crypto Banking Restrictions Lifted in 2025: What the New Rules Mean

US Crypto Banking Restrictions Lifted in 2025: What the New Rules Mean

Michael James 23 February 2025 19 Comments

Crypto Banking Regulation Timeline

Start Date:

End Date:

Key Regulatory Changes in 2025

March 7, 2025

OCC: Issued Interpretive Letter 1183, rescinding IL 1179
National banks can now custody crypto and hold stablecoins without a separate non-objection request.

March 28, 2025

FDIC: Cancelled FIL-16-2022 notification requirement
FDIC-supervised institutions may engage in permissible crypto activities after normal risk-management review.

April 24, 2025

Federal Reserve: Rescinded Supervisory Letters SR 22-6 and SR 23-8
State-member banks and holding companies no longer need advance notice or formal approval for most crypto-asset services.

Impact Summary

Compliance Benefits: Removed regulatory hurdles that previously required advance approvals and lengthy processes.

Market Impact: Enables traditional banks to compete with crypto-fintech firms and reduces compliance costs.

Future Outlook: Regulatory clarity continues with ongoing guidance from the President's Working Group.

On April 24, 2025, the United States took a dramatic step toward normalizing digital‑asset services in traditional finance. The Federal Reserve announced that it was withdrawing the two supervisory letters that had forced banks to ask for prior approval before touching crypto‑assets. That move, echoed by the OCC and the FDIC, effectively ends the era of heavy‑handed crypto banking restrictions that haunted banks for three years.

Why the Cut‑Back Matters

Before the April decision, banks faced a maze of notifications, non‑objection requests, and joint‑statement compliance checks. The rules created a chilling effect: many regional and community banks stayed out of the crypto market altogether, fearing long approval timelines and costly compliance programs. Removing those barriers does three things:

It cuts compliance costs, freeing up staff to focus on product development rather than paperwork.
It levels the playing field, letting traditional banks compete with pure‑play crypto‑fintech firms.
It signals to investors that the federal government now trusts its own supervisory staff to understand digital assets.

Timeline of the Regulatory Rollback

Key Dates and Actions in the 2025 Crypto Banking Shift
Date	Regulator	Action Taken	Impact on Banks
March 7, 2025	Office of the Comptroller of the Currency (OCC)	Issued Interpretive Letter 1183, rescinding IL 1179	National banks can now custody crypto and hold stablecoins without a separate non‑objection request.
March 28, 2025	Federal Deposit Insurance Corporation (FDIC)	Cancelled FIL‑16‑2022 notification requirement	FDIC‑supervised institutions may engage in permissible crypto activities after normal risk‑management review.
April 24, 2025	Federal Reserve Board	Rescinded Supervisory Letters SR 22‑6 and SR 23‑8	State‑member banks and holding companies no longer need advance notice or formal approval for most crypto‑asset services.

The Letters That Got Pulled

SR 22‑6 (2022) demanded that state‑member banks send the Fed a heads‑up before starting any crypto‑related activity. SR 23‑8 (2023) added a formal “non‑objection” step, turning every new token service into a mini‑regulatory filing. Together they created a two‑step gate that many banks simply could not clear. With those gone, the path to offering crypto custody, stablecoin deposits, or even participating in independent node verification networks becomes a standard product‑development decision rather than a regulatory hurdle.

Animated regulatory letters break golden chains, releasing pink petals and butterflies over a city skyline.

What Banks Can Do Now

The new landscape gives banks three clear buckets of permissible activity:

Crypto Custody: Hold customers’ private keys for Bitcoin, Ethereum, or other major tokens, provided the bank has robust cyber‑risk controls.
Stablecoin Services: Accept, hold, or issue stablecoins that are fully backed by fiat reserves, mirroring traditional deposit accounts.
Node Participation: Join independent verification networks (like those under the President's Working Group on Digital Asset Markets) to support blockchain consensus without needing special approval.

All activities remain subject to existing safety‑and‑soundness rules, consumer‑protection statutes, and anti‑money‑laundering (AML) obligations. In practice, that means banks will continue to file regular risk‑assessment reports, but they won’t have to submit separate “crypto‑specific” applications.

Industry Reaction: A Wave of Optimism

Legal firms and industry analysts have praised the coordination. Jones Day called the Fed’s move a “softening of stance” that follows the OCC’s lead. The Fintech Law Blog described the shift as a “permissive stance” that eliminates the “regulatory uncertainty” that had stalled many projects. Latham & Watkins highlighted that the OCC’s reaffirmation of crypto‑custody and stablecoin reserve‑holding “represents a clear departure from the restrictive interpretations of the previous administration.”

From a practical standpoint, banks are already drafting product roadmaps. Early‑stage pilots at a handful of regional banks indicate they plan to launch crypto‑wallet services by Q1 2026, and a few larger institutions have announced intentions to offer stablecoin‑linked checking accounts.

What Still Remains Unclear

Even with the big letters gone, regulators left several gray zones:

Holding non‑stablecoin crypto assets on the balance sheet - the guidance still treats those as high‑risk.
Crypto‑asset lending - no explicit permission or prohibition, meaning banks must tread carefully.
Cross‑border crypto services - the Fed’s statement focused on dollar‑denominated tokens; foreign‑currency crypto may still face separate scrutiny.

All three agencies said they will keep working with the President’s Working Group to flesh out additional guidance. Expect follow‑up releases in late 2025 or early 2026 that address these gaps.

Bank team launches crypto custody service, with holographic tokens and glowing coins swirling in a pastel office.

Steps for Banks Ready to Jump In

For a bank that wants to act now, a practical six‑step checklist can keep the rollout smooth:

Risk Assessment: Map out crypto‑related risks (cyber, market, compliance) and compare them to existing risk‑management frameworks.
Policy Update: Amend internal policies to reference the new supervisory guidance and remove any legacy “notification” clauses.
Technology Stack: Choose a custody provider or develop in‑house key‑management tools that meet federal cybersecurity standards.
Staff Training: Ensure compliance, AML, and front‑office teams understand the new product rules and reporting obligations.
Pilot Launch: Start with a limited customer segment (e.g., high‑net‑worth clients) to test operational flows.
Regulatory Review: File the standard supervisory report that now includes a crypto‑risk section, but no separate non‑objection request.

Following this pathway lets banks move quickly while staying within the “normal supervisory processes” that the Fed now emphasizes.

Looking Ahead: A More Integrated Financial System?

Analysts are already speculating about the broader impact. If traditional banks capture even a modest share of the crypto‑custody market, the total addressable market could add $50‑$70billion in assets under management by 2028. That influx would bring more institutional discipline to the crypto ecosystem and could push stablecoins toward wider acceptance as a “digital dollar.” At the same time, the regulatory vacuum around crypto‑lending could spark a new wave of fintech‑bank partnerships, where banks provide the back‑office compliance while fintechs handle the front‑end user experience.

In short, the 2025 rollback doesn’t just remove paperwork - it opens a gateway for banks to become a mainstream part of the digital‑asset economy.

Frequently Asked Questions

What exactly did the Federal Reserve rescind?

The Fed withdrew Supervisory Letters SR22‑6 (advance‑notice requirement) and SR23‑8 (non‑objection process). Banks no longer need to file special notifications before offering most crypto‑related services.

Can national banks now hold any crypto on their balance sheets?

Not yet. The current guidance still treats non‑stablecoin tokens as high‑risk. Banks may hold stablecoins, but broader crypto‑asset balance‑sheet treatment will need additional guidance.

How does the OCC’s Interpretive Letter 1183 change things for banks?

Letter1183 removes the requirement for a “supervisory non‑objection” before banks engage in crypto custody, stablecoin holdings, or node participation, effectively treating these activities like any other banking service.

Will the FDIC still review crypto activities?

Yes. The FDIC’s new guidance says institutions may proceed without prior approval, but they must still manage risks and comply with AML and consumer‑protection rules, which are reviewed in regular supervisory exams.

What gaps should banks watch for in the future?

Key gaps include guidance on crypto‑lending, balance‑sheet treatment of non‑stablecoin assets, and cross‑border token services. Expect further clarification from the President’s Working Group later this year.