frb – FinTech and Blockchain Law Watch

Federal Banking Regulators Adopt a Permissive Stance on Cryptocurrency

Apr 29 2025

By: Grant Bulter , Richard Kerr, and Win Gustin

The federal banking regulators have each recently adopted a more permissive approach to the regulation of cryptocurrency activities within the banking sector. The Office of the Comptroller of the Currency (OCC), the Federal Deposit Insurance Corporation (FDIC) and the Board of Governors of the Federal Reserve System (FRB) have issued new guidance that relaxes previous restrictions and requirements for banks engaging in crypto-related activities. The three agencies have also withdrawn two interagency statements, the Joint Statement on Crypto-Asset Risks to Banking Organizations (3 January 2023) and the Joint Statement on Liquidity Risks to Banking Organizations Resulting from Crypto-Asset Market Vulnerabilities (23 February 2023).

Federal Reserve Doubles Down on Oversight of Crypto Activities for Banks

Aug 18 2022

By Grant F. Butler, Jeremy McLaughlin, Anthony R.G. Nolan, and Judie Rinearson

The Federal Reserve Board (the “FRB”) issued Supervision and Regulation Letter 22-6 (“SR 22-6”), providing guidance for FRB-supervised banking organizations (referred to collectively herein as “FRB banks”) seeking to engage in activities related to cryptocurrency and other digital assets. The letter states that prior to engaging in crypto-asset-related activities, such FRB banks must ensure that their activities are “legally permissible” and determine whether any regulatory filings are required. SR 22-6 further states that FRB banks should notify the FRB prior to engaging in crypto-asset-related activities. Any FRB bank that is already engaged in crypto-asset-related activities should notify the FRB promptly regarding the engagement in such activities, if it has not already done so. The FRB also encourages state member banks to contact state regulators before engaging in any crypto-asset-related activity.

Let Me In: Wyoming Special Purpose Bank Sues Fed for Access to Payments System

Jun 10 2022

By Grant F. Butler, Andrew M. Hinkes, and Robert M. Tammero, Jr.

Custodia Bank (“Custodia”) filed a complaint against the Federal Reserve Board (“FRB”) and the Federal Reserve Bank of Kansas City (“FRBKC”) in Wyoming federal court alleging that the FRB and FRBKC are unlawfully refusing to act on Custodia’s application for a master account. A Federal Reserve master account allows banks to directly access the Federal Reserve and utilize the Federal Reserve System’s payment, clearing and settlement services.

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