The head of the US Office of the Comptroller of the Currency warns banks: Refusing crypto custody is "self-destruction"

One of the highest banking regulators in the US, the Office of the Comptroller of the Currency (OCC), has issued a clear and stern warning through its chief, Jonathan Gould. On December 10, speaking at the Blockchain Association Policy Summit, he declared that traditional banking groups trying to block national trust banks from offering crypto custody services are following a “recipe for irrelevance.” Citing data, he noted that as of Q3 2025, national trust banks managed nearly $2 trillion in non-custodial assets, accounting for 25% of their total assets under management. His statement strongly supports the efforts of crypto companies like Coinbase and Ripple to apply for national trust bank charters, marking a high-level regulatory push in the US to deeply integrate traditional finance with digital assets.

OCC Chief’s Hardline Declaration: Embrace Innovation or “Self-Destruct”?

“Locking banks, including existing national trust banks, into outdated technologies or business models is a recipe for irrelevance.”

Jonathan Gould, Comptroller of the Currency, delivered this unequivocal rebuke to conservative forces trying to exclude cryptocurrencies from the traditional banking system. At the Blockchain Association Policy Summit in Washington, this chief regulator of national banks defended banks’ participation in crypto asset custody services with an unusually forceful stance.

Gould’s remarks targeted the recent collective resistance from banking industry groups against crypto companies applying for national trust bank charters. The Independent Community Bankers of America and the Bank Policy Institute had previously written to the OCC, urging it to reject applications from firms like Coinbase and Sony Bank’s Connectia Trust, claiming these applications were “regulatory loophole exploitation” and an “impermissible reinterpretation” of federal law. Gould dismissed these assertions, pointing out that national trust banks have been engaged in non-custodial business since the 1970s—this is not new, but a natural progression of banking.

He backed up his argument with striking data: in just Q3 this year, national trust banks reported nearly $2 trillion in non-custodial assets, accounting for 25% of total assets under management. He emphasized, “Prohibiting national trust banks from engaging in non-custodial activities could undermine the dynamic and evolving nature of the federal banking system and disrupt more than $1 trillion of existing traditional activities by national trust banks.” His reasoning is clear and compelling: crypto asset custody is simply a shift from holding electronic stock certificates to digital assets on a blockchain; fundamentally, there’s no difference, so “there is absolutely no reason to treat digital assets differently.”

OCC Position and Key Information on Crypto Bank Charter Applications

OCC Core Positions and Data:

• Regulatory Stance: Strongly supports national trust banks conducting digital asset custody and other crypto-related business, viewing it as a natural industry evolution.
• Historical Basis: National trust banks have engaged in non-custodial business since the 1970s.
• Current Data (2025 Q3): National trust banks manage nearly $2 trillion in non-custodial assets, representing 25% of their total assets under management.
• Precedent: State-chartered trust companies in New York and South Dakota already offer digital asset custody; Anchorage Digital, as a “crypto-native national trust bank,” is under OCC supervision (its compliance order was lifted in August).
• Application Boom: 14 new bank charter applications received in 2025, nearly matching the total from the previous four years and reversing a 15-year slump in applications.

Crypto Companies Applying for National Trust Bank Charters (Partial List):

• Coinbase
• Circle
• Ripple
• Bridge (Stripe’s stablecoin division)
• Paxos
• Sony Bank (Connectia Trust)
• Conditional Approval Granted: Erebor Bank (approved last month)

Demystifying “Custody”: The $2 Trillion Market and Banks’ Real Role

Why is Comptroller Gould going to such lengths to legitimize “crypto custody”? To understand, one must first clarify what “custody” really means in traditional finance and its immense scale. In banking, “custody” is far more than just holding physical gold bars or paper stock certificates. It encompasses a suite of asset services for institutional clients (like hedge funds, pensions, and family offices), including safekeeping, settlement, income collection, and corporate action processing. Once assets are digitized, banks safeguard electronic records and access rights.

Gould noted that banks have been holding electronic rights to company shares for decades. Thus, switching from “electronic records of company stock” to “ownership records of bitcoin on a blockchain” is not a revolutionary change in technology or risk. The real challenge is for banks to develop secure, compliant technology systems to manage blockchain private keys and adapt to a 24/7 settlement cycle. This is more an operational and technological upgrade than a disruptive legal or business model change.

The OCC’s latest guidance goes further, explicitly allowing banks to act as “riskless principal” intermediaries in crypto transactions. In this model, banks act as brokers, buying crypto from one party and selling to another, without holding inventory themselves (except in rare cases), thus avoiding direct market risk. This opens the door for traditional banks to safely participate in the crypto economy and earn fee income, addressing concerns about the risks of banks directly holding volatile crypto assets.

Traditional Banks at a Crossroads: Fear Competition or Embrace the Future?

Gould’s strong remarks reveal a deep rift and anxiety within the US banking sector. Traditional institutions, especially community banks, are motivated by multiple fears. First is the fear of “disintermediation”—that stablecoins and decentralized finance (DeFi) could bypass the banking system, draining deposits and payment business, threatening their core interest margins. Second is the fear of “compliance and risk,” with anxieties about crypto volatility, anti-money laundering complexities, and technological barriers.

However, Gould offers another perspective: crypto technology can be a tool, not just a threat. He has suggested that stablecoins could help community banks compete with larger institutions. For example, banks could use stablecoins to provide faster, cheaper cross-border payments and attract new customers. Offering crypto custody as a service could draw a new generation of high-net-worth clients or institutional investors, becoming a new revenue growth engine.

At a deeper level, this debate is about the future competitiveness of US banking. OCC data shows that after 15 years of stagnation, new bank charter applications surged to 14 in 2025, many involving digital asset business. Gould warns that regulatory roadblocks to such innovation are “short-sighted,” “legally unsound, and lead to a decline in banking vitality and competitiveness.” If the US national banking system refuses to serve next-generation, digital-native financial companies, these firms—and the capital, innovation, and jobs they bring—could easily flow to more crypto-friendly offshore jurisdictions or emerging state-chartered trust companies.

Regulatory Paradigm Shift: From “Pre-Approval” to “Permissioned Innovation”

The OCC’s current active approach marks a fundamental shift in US bank regulatory philosophy under the Trump administration. Recall that under the Biden administration, the OCC issued guidance requiring banks to seek pre-approval from regulators before deep involvement in crypto, taking a cautious, even conservative stance. Now, under Gould’s leadership, the OCC has not only withdrawn many restrictions but also proactively clarified the permissible scope of activities and publicly supported crypto companies’ bank charter applications.

This shift aligns with the White House’s broader policy direction. President Trump and his family members have shown a friendly, even participatory, attitude toward cryptocurrencies, pushing agencies including the SEC to revisit rules and tear down barriers. The goal is clear: close the gap between traditional finance and crypto activities and ensure the US leads in the digital financial era.

Of course, criticism continues. Opponents argue that this rapid integration between tightly regulated traditional finance and the volatile, relatively lightly regulated crypto world could create unknown “systemic risks.” However, the OCC’s stance appears to be: rather than banning out of fear and driving risks into the regulatory shadows (“shadow banking”), it’s better to bring these activities into the federal banking system’s supervisory framework, ensuring transparency and prudent oversight under the principles of “safety and soundness.” The ongoing supervision of Anchorage Digital until it achieved compliance is an example of this approach in action.