Crypto-Asset Safekeeping: What’s Involved If You’re a Bank (or if You Want to Be One) | Morrison & Foerster LLP

On July 14, 2025, the federal banking agencies[1] issued a joint statement to clarify regulatory expectations for banking organizations that provide or are considering providing safekeeping for crypto-assets (“Joint Statement”).[2] After providing some key takeaways, this alert analyzes the Joint Statement and considers what is next for banking organizations and others seeking to engage in crypto-asset safekeeping.

Key Takeaways

  • Safekeeping defined. Safekeeping refers to the service of holding an asset on a customer’s behalf. In the context of crypto-assets, this means controlling the cryptographic keys associated with the crypto-asset in a way that complies with applicable laws and regulations.
  • Common baseline. While the…

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