U.S. Banking Agencies Issue Roadmap for Crypto Regulation

On November 23, 2021, the U.S. federal banking agencies issued a joint statement on their “crypto sprint” initiative, an inter-agency project to address bank and bank holding company participation in crypto-asset-related businesses. 

The statement provides a useful overview of the Agencies’ recent crypto-related efforts and includes a roadmap of priorities for the coming year.  It remains to be seen whether the crypto sprint is a harbinger of new regulations or whether the agencies will continue to adapt existing regulations and interpretations to new activities. On the same day, the OCC issued Interpretive Letter 1179, which confirms that it remains permissible for national banks to engage in the cryptocurrency, distributed ledger and stablecoin activities addressed in previous OCC letters on these topics. However, the OCC modified the overall outcome of those previous letters by requiring prior approval from a national bank’s examiner-in-charge before commencing these crypto-related activities.

Our Memorandum provides an overview of these developments, highlighting key takeaways.