A Potential Turning Point for Digital Assets Custody : US Banking Regulators Issue Joint Guidance

On July 14, 2025, the U.S. banking landscape took a significant step toward embracing the digital assets and blockchain ecosystem. Blockdaemon has shared key insights following the announcement.

As covered, the Federal Reserve, the Federal Deposit Insurance Corporation (FDIC), and the Office of the Comptroller of the Currency (OCC)—collectively known as the “big three” banking regulators—issued a joint statement clarifying expectations for banks providing crypto-asset safekeeping services.

This guidance, while not introducing new regulations, marks a pivotal moment in the integration of cryptocurrencies into traditional banking systems, potentially reshaping the future of crypto custody.

The joint statement emphasizes that banks can hold crypto assets, such as Bitcoin and Ethereum, for customers in both fiduciary and non-fiduciary capacities, provided they adhere to existing risk management frameworks and comply with applicable laws.

Safekeeping, defined as controlling the cryptographic keys associated with a crypto asset, demands robust cybersecurity, operational expertise, and adherence to legal standards like the Bank Secrecy Act (BSA), anti-money laundering (AML) regulations, and Office of Foreign Assets Control (OFAC) requirements.

Banks must ensure exclusive control over these keys, demonstrating that no other party, including the customer, can unilaterally access or transfer the assets.

This guidance arrives at a critical juncture.

The rescission of the Securities and Exchange Commission’s Staff Accounting Bulletin 121 (SAB 121) on January 23, 2025, removed a significant barrier that had previously discouraged banks from engaging in crypto custody due to stringent accounting rules.

The new statement reflects a shift in regulatory tone under the Trump administration, moving away from the restrictive policies of the Biden era, which had constrained banks’ interactions with the crypto industry.

This change aligns with broader legislative efforts, such as the U.S. House of Representatives’ “Crypto Week,” where lawmakers are expected to approve multiple crypto-related bills to establish formal digital asset regulations.

For banks, the guidance underscores the importance of comprehensive risk assessments before offering crypto safekeeping services.

These assessments must evaluate the technical, operational, legal, market, and strategic characteristics of each crypto asset, requiring banks to establish internal digital-asset review committees with specialized expertise.

The statement also highlights the need for clear customer agreements that address unique aspects of crypto custody, such as on-chain governance, forks, airdrops, and the use of hot, cold, or hybrid storage methods.

Banks remain fully accountable for assets, even when outsourcing to third-party sub-custodians, necessitating rigorous due diligence and ongoing monitoring.

The implications for the crypto industry are potentially profound.

By allowing banks to compete directly with crypto-native custodians, the guidance could drive institutional adoption of digital assets.

Traditional banks, with their decades of custodial experience and regulatory compliance infrastructure, are positioned to challenge providers like Blockdaemon, which has been a key player in institutional-grade blockchain infrastructure.

Blockdaemon’s CEO, Konstantin Richter, has long advocated for governance and security to build trust in the crypto space, a stance that aligns with the regulators’ emphasis on robust controls.

However, the entry of banks could intensify competition, potentially lowering costs and improving service quality for institutional clients.

Critics argue that the guidance, while clarifying, imposes heavy oversight that may deter smaller banks from entering the market.

The requirement for specialized staff, secure infrastructure, and constant monitoring of evolving technologies could favor larger institutions with greater resources.

Additionally, the omission of guidance on account titling raises concerns, given its importance in determining customer ownership rights during insolvency—a critical issue highlighted by high-profile crypto bankruptcies in 2022.

Nevertheless, Blockdaemon indicates that the joint statement signals a maturing regulatory environment that balances innovation with safety.

By treating crypto safekeeping within the same framework as traditional custodial assets, regulators are seemingly paving the way for banks to play a central role in the digital asset ecosystem.

As banks reevaluate their strategies in light of SAB 121’s rescission, the guidance could catalyze a new era of digital assets custody.

Whether this is merely another piece of guidance or a true turning point will depend on how banks seize this opportunity to bridge traditional finance and the crypto sector.



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