On July 14, 2025, the Federal Reserve, the OCC, and the FDIC issued a joint statement addressing risk management and legal expectations applicable to banking organizations engaging in crypto-asset safekeeping. The Statement follows the Agencies’ coordinated rescission earlier this year of interpretive guidance requiring advance supervisory non-objection for crypto activities. While the Statement does not impose new regulatory requirements, it provides important guidance regarding how the Agencies expect banking organizations to manage the legal, operational, technological, and compliance risks associated with crypto-asset safekeeping.

Click here to read the full GT Alert.

Tags: cryptocurrency, FDIC, Federal Reserve Systems, GT Insight, OCC
Print:
Email this postTweet this postLike this postShare this post on LinkedIn
Photo of Marina Olman-Pal Marina Olman-Pal

Marina Olman-Pal, Co-Chair of the firm’s Financial, Regulatory & Compliance Practice, advises foreign and U.S. financial institutions on a broad range of regulatory matters including licensing, acquisitions, divestitures, compliance with Bank Secrecy Act (BSA)/anti-money laundering (AML) laws and regulations, and compliance with Office…

Marina Olman-Pal, Co-Chair of the firm’s Financial, Regulatory & Compliance Practice, advises foreign and U.S. financial institutions on a broad range of regulatory matters including licensing, acquisitions, divestitures, compliance with Bank Secrecy Act (BSA)/anti-money laundering (AML) laws and regulations, and compliance with Office of Foreign Assets Control (OFAC) sanctions programs. Marina counsels a wide range of companies in the financial services sector including, domestic and foreign banks, gaming companies, money services businesses including money transmitters, cryptocurrency businesses, Fintech companies and digital payment companies. Throughout her career, Marina has represented clients before U.S. regulators such as the Federal Reserve, OCC, FDIC, FinCEN, OFAC, the Florida Office of Financial Regulation and other state supervisory authorities. Marina also regularly develops anti-money laundering programs for a wide range of financial services businesses and non-financial services businesses including, U.S. and foreign companies active in industries such as real estate, hospitality, automotive and artificial intelligence, among many others.

Read more about Marina Olman-Pal
Show more Show less
Photo of Jera L. Bradshaw Jera L. Bradshaw

Jera L. Bradshaw is a former state and federal regulator who advises community, regional, and national banks on all aspects of financial regulatory compliance and enforcement, with an emphasis on state and federal enforcement actions; corporate and board governance matters related to regulatory

…

Jera L. Bradshaw is a former state and federal regulator who advises community, regional, and national banks on all aspects of financial regulatory compliance and enforcement, with an emphasis on state and federal enforcement actions; corporate and board governance matters related to regulatory compliance, bank-fintech partnerships, regulatory applications, enterprise risk; and “troubled” banks.

Jera regularly assists financial institutions of all sizes with examinations, applications, and enforcement matters; has an extensive background advising banks on compliance and remediation programs; and is experienced appearing before the Federal Deposit Insurance Corporation (FDIC), the Office of the Comptroller of the Currency (OCC), the Board of Governors of the Federal Reserve System (FRB), the Consumer Financial Protection Bureau (CFPB), and multiple state bank regulatory authorities.

Before joining private practice, Jera served ten years as bank regulatory counsel to the FDIC and the Tennessee Department of Financial Institutions (“TDFI”) where she conducted legal review of regulatory filings such as branch applications, golden parachute payments, mergers, brokered deposit waivers, changes in bank control, and retirement of capital; supported regulatory examinations; oversaw enforcement actions; and advised on legislation, laws, and policies affecting financial institutions.

More recently, she acted as senior counsel of regulatory affairs for a large regional bank advising on intricate legal issues affecting the enterprise including implementation of enhanced prudential standards, affiliate transactions, dividend restrictions, Community Reinvestment Act strategy, and consumer compliance management systems (“CMS”).

Jera leverages her deep bank regulatory experience to deliver practical legal advice on a range of financial regulatory topics including affiliate transactions, deposit products, BSA/AML compliance, lending limits, insider transactions, capital and liquidity risk management, and the Community Reinvestment Act. She counsels clients on regulatory aspects of new product development, including bank partnership models, BaaS relationships, payment systems, fintech deposit platforms and third-party oversight. She also advises bank acquirers and sellers on regulatory approvals for M&A transactions, noncontrolling investments, nonbank activities, and other complex issues.

Jera is chair of the American Bar Association’s Regional and Community Banks Subcommittee, a faculty member of Fundamentals of Banking Law, and a guest lecturer at the SMU Dedman School of Law. In addition to speaking on regulatory issues affecting insured depository institutions, Jera is routinely called upon to train bank boards and management on a wide range of legal and risk management topics.

Show more Show less
Photo of Nathan M. Iacovino Nathan M. Iacovino

Nathan M. Iacovino focuses his practice on the investment servicing and investment management industries, advising asset-servicing entities, including custodians, transfer agents, and administrators, in connection with various regulatory and transactional matters. He has supported and developed strategies related to the structuring, negotiation, and

…

Nathan M. Iacovino focuses his practice on the investment servicing and investment management industries, advising asset-servicing entities, including custodians, transfer agents, and administrators, in connection with various regulatory and transactional matters. He has supported and developed strategies related to the structuring, negotiation, and implementation of domestic and global custody, fund administration, managed account platforms, collateral management, and related servicing arrangements by and among his custodial, investment servicing and managed account platform provider clients and their respective fund, investor, pension plan, and adviser client base.

Nathan also represents mutual fund complexes, asset managers, investment advisers, institutional investors and financial institutions in developing and maintaining financial products while navigating the regulatory landscape.

Nathan’s clients include a wide range of private funds, registered investment companies, transfer agents, banks, financial institutions, institutional investors and investment advisors.

Read more about Nathan M. IacovinoNathan's Linkedin Profile
Show more Show less
Related Posts
shutterstock_680368252
SEC Approves In-Kind Creations and Redemptions for Crypto ETPs
July 30, 2025
cryptocurrency in the form of coins
GENIUS Act Enacted, Establishing a Regulatory Framework for Payment Stablecoins Issued or Sold in the United States
July 22, 2025
shutterstock_616226957
Federal Reserve and FDIC Withdraw Crypto-Asset Guidance for Banks; OCC Issues Clarification for Banks
May 16, 2025