Growing demand for blockchain-based payments is reshaping how banks manage digital-asset transactions. The Office of the Comptroller of the Currency (OCC) issued Interpretive Letter #1186 on Nov. 18, 2025, clarifying when national banks may retain crypto-assets as principal to address network-fee obligations tied to otherwise permissible activities.

The OCC stated on social media platform X:

The OCC confirmed permissible bank activities related to paying crypto-asset network fees, sometimes referred to as ‘gas fees.’

The OCC letter states: “Based on the foregoing facts, representations, and analysis, the bank’s proposal to pay network fees to facilitate otherwise permissible crypto-asset activities and to hold, as principal, amounts of crypto-assets on balance sheet necessary to pay network fees for which the bank anticipates a reasonably foreseeable need is permissible for the bank.”

The agency explained that distributed ledger systems often require native-token fees to execute transfers, reconcile custodial balances, and complete customer-directed transactions. Without access to those tokens, banks could face delays, higher costs, or dependence on third-party intermediaries.

The OCC reviewed parallels to long-standing banking roles in foreign exchange and payment networks, treating blockchain rails as modern extensions of established financial infrastructure. It also noted that banks must maintain crypto holdings at de minimis levels, align them with foreseeable needs, and apply controls covering cybersecurity, liquidity, illicit finance, and legal exposure.

Read more: OCC Declares US Banking System ‘Well Positioned’ to Embrace Crypto

The agency extended its reasoning to testing environments, citing its second conclusion:

Similarly, the bank may hold amounts of crypto-assets as principal necessary for testing otherwise permissible cryptoasset-related platforms, whether internally developed or acquired from a third party.

The letter detailed that effective validation of custody, execution, or payments systems is essential for safety and soundness and that relying on external token providers could introduce operational and counterparty risks. Although the OCC outlined elevated technological and market complexities, supporters contend that allowing banks to source and manage limited network-fee assets directly could enhance efficiency, streamline settlement, and reduce reliance on intermediaries across emerging blockchain-based financial services.

• How does the OCC guidance potentially boost bank competitiveness in blockchain payments?
  It allows banks to hold limited crypto-assets needed for network fees, reducing friction and dependence on intermediaries.
• Why is the ability to retain native tokens important for investor-focused blockchain adoption?
  It enables smoother, lower-cost execution of digital-asset transactions, strengthening institutional infrastructure.
• What operational advantage do banks gain from holding crypto for testing environments?
  They can validate platforms internally without third-party delays, improving reliability and speed-to-market.
• How could these permissions influence long-term digital-asset service growth?
  Expanded clarity may accelerate bank-level integration of blockchain rails and broaden high-confidence use cases for investors.

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