🧠 Food for thought

Implications, context, and why it matters.

Citi’s 2026 plan depends on meeting Office of the Comptroller of the Currency (OCC) expectations

• The OCC is the primary U.S. regulator for national banks and it scrapped the supervisory nonobjection (an advance “no‑objection” letter) step in March 2025 for crypto custody 1
• In May 2025, the OCC said banks can hold crypto assets and use sub‑custodians (specialist firms that hold assets for a custodian bank) if they manage risk 2. Activities must be conducted “in a safe and sound manner and in compliance with applicable law” 2
• Anchorage Digital, a federally chartered U.S. crypto bank, faced a long approval path even with supportive policy 3
• Citi has a multi‑year plan that weighs in‑house builds with third‑party options. The bank is addressing OCC expectations on controls, cybersecurity, and operational resilience that interpretive letters (formal guidance documents) do not fully detail

Vendors with bank‑grade certifications and compliance gain as custody demand grows

• The OCC permits banks to outsource crypto custody to third parties, which creates a market for tech that meets bank‑grade standards 2
• Vendors and investors should favor providers serving regulated institutions because Citi referenced “lightweight, nimble” third‑party tools, which signals banks will pick compliance over building in‑house
• May 2025 guidance that banks can use sub‑custodians opens room for wallet infrastructure (key management software and hardware), multi‑party computation (MPC) security, plus chain analytics (blockchain transaction monitoring for compliance) 4
• Investors can scan custody stacks that hold certifications or serve institutions like Anchorage Digital to gauge partnership readiness 3