FIL-16-2022 Notification of Engaging in Crypto-Related Activities
Document text
Research, not advice. Part of the Bitcoin research archive (October 2026). Claims labelled unverified, contested or fringe are reported, not endorsed; statuses of bills and rules are as of the date checked. Government, court and patent records are public domain; the research notes are CC BY 4.0.
Notification of Engaging in Crypto-Related Activities | FDIC.gov
Skip to main content
An official website of the United States government
Here’s how you know
Here’s how you know
Official websites use .gov
A .gov website belongs to an official government organization in the United States.
Secure .gov websites use HTTPS
A lock (
) or https:// means you’ve safely connected to the .gov website. Share sensitive information only on official, secure websites.
Cambiar a español
Search FDIC.gov
Search
About
Toggle submenu
Toggle submenu
About
The Federal Deposit Insurance Corporation (FDIC) is an independent agency created by the Congress to maintain stability and public confidence in the nation’s financial system. Learn about the FDIC’s mission, leadership, history, career opportunities, and more.
Learn More About the FDIC
What We Do
Leadership
Careers
Initiatives
Workplace Culture
Strategic Plans
Financial Reports
History
Governance
Ombudsman
Doing Business with the FDIC
Resources
Toggle submenu
Toggle submenu
Resources
The FDIC provides a wealth of resources for consumers, bankers, analysts, and other stakeholders. Browse our collection of financial education materials, data tools, documentation of laws and regulations, information on important initiatives, and more.
Additional FDIC Resources
Consumer Resource Center
Banker Resource Center
Deposit Insurance
Supervision & Examinations
Laws & Regulations
Resolutions
Publications
Forms
Data Tools
Community Banking Research Program
International Seminars and Training
Analysis
Toggle submenu
Toggle submenu
Analysis
The FDIC is proud to be a pre-eminent source of U.S. banking industry research, including quarterly banking profiles, working papers, and state banking performance data. Browse our extensive research tools and reports.
More FDIC Analysis
Quarterly Banking Profile
Banking Issues in Focus
Center for Financial Research
Consumer Research
FDIC National Survey of Unbanked and Underbanked Households
Annual Risk Review
EVENT / August 25, 2026
FDIC-Insured Institutions Reported Return on Assets of 1.37 Percent and Net Inc…
REPORT / June 02, 2026
National rates and rate caps for June 2026 released.
EVENT / May 27, 2026
The banking industry reported a return on assets ratio of 1.26, an increase of …
REPORT / April 22, 2026
2026 Risk Review, an overview of funding, interest rate, and credit risks banks…
News
Toggle submenu
Toggle submenu
News
The FDIC publishes regular updates on news and activities. Keep up with FDIC announcements, read speeches and testimony on the latest banking issues, learn about policy changes for banks, and get the details on upcoming conferences and events.
Find More FDIC News
Press Releases
Financial Institution Letters
Conferences & Events
Board Matters
Natural Disasters
Media Campaigns
Speeches, Statements & Testimonies
Podcasts
Videos
Opinion Editorials
Policy Fact Sheets
PRESS RELEASE / October 05, 2026
FDIC Issues List of Banks Examined for CRA Compliance
PRESS RELEASE / September 30, 2026
FDIC Announces Conclusion of Independent Monitorship
PRESS RELEASE / September 29, 2026
Agencies Publish Resolution Plan Feedback Letters for 15 Banking Organizat…
PRESS RELEASE / September 25, 2026
Sunwest Bank Assumes All Deposits and Certain Assets of Nano Banc, Irvine,…
Search
Toggle submenu
Search FDIC.gov
Search
Advanced Search
Home
News
Inactive Financial Institution Letters
2022
INACTIVE
This page is no longer active. Its content has expired or been rescinded by the FDIC.
Notification of Engaging in Crypto-Related Activities
Miscellaneous
April 7, 2022
Share on Facebook
Share on X
Follow the FDIC on LinkedIn
Share through email
Print
Summary:
All FDIC-supervised institutions that intend to engage in, or that are currently engaged in, any activities involving or related to crypto assets (also referred to as “digital assets”) should notify the FDIC. FDIC-supervised institutions are requested to provide information described in this letter. The FDIC will review the information and provide relevant supervisory feedback.
A copy of the letter can be found on the FDIC’s website.
Statement of Applicability: The contents of, and material referenced in, this FIL apply to all FDIC-supervised financial institutions.
Highlights:
While the FDIC supports innovations that are safe and sound, in compliance with laws and regulations, and fair to consumers, the FDIC is concerned that crypto assets and crypto–related activities are rapidly evolving, and risks of this area are not well understood given the limited experience with these new activities.
Crypto–related activities may pose significant safety and soundness risks as well as financial stability concerns.
Crypto–related activities present risks to consumers, and insured depository institutions face risks in effectively managing the application of consumer protection laws and regulations to new and changing crypto–related activities.
Pursuant to Section 39 of the Federal Deposit Insurance Act (FDI Act), the FDIC has established in Part 364 (including Appendices A and B) safety and soundness standards for all FDIC–supervised institutions.
An FDIC–supervised institution that engages, or intends to engage in, any crypto–related activities should notify the FDIC and provide any information requested by the FDIC that will allow the agency to assess the safety and soundness, consumer protection, and financial stability implications of such activities.
The FDIC will review the relevant information submitted by the FDIC–supervised institution related to crypto-related activities and provide relevant supervisory feedback to the institution, as appropriate.
April 7, 2022 FIL-16-2022
Notification and Supervisory Feedback Procedures for FDIC-Supervised Institutions Engaging in Crypto-Related Activities
Background and Scope1
The FDIC is issuing this letter to address the engagement by FDIC-supervised institutions in crypto-related activities.2 Crypto-related activities may pose significant safety and soundness risks, as well as financial stability and consumer protection concerns. Moreover, these risks and concerns are evolving as crypto-related activities are not yet fully understood.
The FDIC notes that there is little consistency in the definitions associated with many crypto assets and crypto-related activities, which makes it difficult to categorically identify these assets and activities. Further, the structure and scope of these activities are rapidly changing and expanding. As a result of the dynamic nature of crypto-related activities, it is difficult for institutions, as well as the FDIC, to adequately assess the safety and soundness, financial stability, and consumer protection implications without considering each crypto-related activity on an individual basis. Therefore, the FDIC is requesting all FDIC-supervised institutions that are considering engaging in crypto-related activities to notify the FDIC of their intent and to provide all necessary information that would allow the FDIC to engage with the institution regarding related risks. Any FDIC-supervised institution that is already engaged in crypto-related activities should promptly notify the FDIC. Institutions notifying the FDIC are also encouraged to notify their state regulator.
Risk Considerations
Below is a description (not all-inclusive) of some of the crypto-related risks about which the FDIC is concerned. Different risks may apply differently to various activities.
Safety and Soundness
Crypto-related activities present new, heightened, or unique credit, liquidity, market, pricing, and operational risks that could present safety and soundness concerns. For example, there are fundamental ownership issues, including whether it is possible for ownership to be clearly validated and confirmed. Further, there are significant anti-money laundering/countering the financing of terrorism implications and concerns related to crypto assets, including reported instances of crypto assets being used for illicit activities. Relatedly, there are implications to information technology (IT) and information security, including IT risk exposure and whether sufficient frameworks are available, in relation to the level of risk, to maintain the confidentiality, integrity, and availability of information systems.
There are concerns about the credit risk exposure posed by the crypto asset or the structure that the asset is held in, including whether it is possible to measure the degree of asset quality, credit risk, and counterparty risk exposure. This also includes whether it is possible to determine whether the asset is bankable3 and whether it is possible for insured depository institutions to manage those risks and exposures. Significant market risk is also evident, as it is uncertain whether adequate methods for pricing and valuation exist. Moreover, accounting, auditing, and financial reporting treatment of crypto assets and crypto-related activities is evolving. There are also significant liquidity implications for insured depository institutions, such as liquidity risk exposure (particularly when crypto assets with very volatile values are involved).
Financial Stability
The FDIC is concerned that certain crypto assets or crypto-related activities may pose systemic risks to the financial system. Systemic risks could be created as an unintended consequence resulting from the structure of a crypto asset or through the interconnected nature of certain crypto-related activities. For example, a disruption in crypto-asset transactions or crypto-related activities could result in a “run” on financial assets backing a crypto asset or crypto-related activity. Like other runs, this could create a self-reinforcing cycle of redemptions and fire sales of financial assets, which, in turn, could disrupt critical funding markets. Further, operational failures related to crypto assets or crypto-related activities could have a destabilizing effect on the insured depository institutions engaging in such activities.
Consumer Protection
The FDIC is concerned about risks to consumers related to crypto-related activities. For example, the FDIC is concerned about the risk of consumer confusion regarding crypto assets offered by, through, or in connection with insured depository institutions, as consumers may not understand the role of the bank or the speculative nature of certain crypto assets as compared to traditional banking products, such as deposit accounts. In addition, insured depository institutions face risks in effectively managing the application of consumer protection requirements, including laws related to unfair or deceptive acts or practices, to new and changing crypto-related activities.
Notification of Engagement in Crypto-Related Activities
Prior to engaging in, or if currently engaged in, a crypto-related activity, an FDIC-supervised institution promptly should notify the appropriate FDIC Regional Director. The FDIC will request that the institution provide information necessary to allow the agency to assess the safety and soundness, consumer protection, and financial stability implications of such activities. The information requested by the FDIC will vary on a case-specific basis depending on the type of crypto-related activity. However, the initial notification to the FDIC Regional Director should describe the activity in detail and provide the institution’s proposed timeline for engaging in the activity.
Upon receipt, the FDIC will review the notification and information received, request additional information as needed, and consider the safety and soundness, financial stability, and consumer protection considerations of the proposed activity. The FDIC will provide relevant supervisory feedback to the FDIC-supervised institution, as appropriate, in a timely manner.
Legal Implications
Pursuant to Section 39 of the FDI Act, the FDIC has established in Part 364 (including Appendices A and B) safety and soundness standards for all FDIC-supervised institutions.4 As noted, activities involving new and rapidly emerging technologies can amplify risk to the insured depository institutions themselves, consumers, and the Deposit Insurance Fund. FDIC-supervised institutions should be able to demonstrate their ability to conduct crypto-related activities in a safe and sound manner.
1This FIL does not address the permissibility of any specific crypto-related activity that an FDIC-supervised institution may engage in under Section 24 or Section 28 of the Federal Deposit Insurance Act (FDI Act) or under Part 362 of the FDIC’s Rules and Regulations.
2By “crypto asset,” the FDIC refers generally to any digital asset implemented using cryptographic techniques. The term of “crypto-related activities” for the purposes of this FIL includes acting as crypto-asset custodians; maintaining stablecoin reserves; issuing crypto and other digital assets; acting as market makers or exchange or redemption agents; participating in blockchain- and distributed ledger-based settlement or payment systems, including performing node functions; as well as related activities such as finder activities and lending. This listing is based on known existing or proposed crypto-related activities engaged in by FDIC-supervised institutions, but given the changing nature of this area, other activities may emerge that fall within the scope of this FIL. The inclusion of an activity within this listing should not be interpreted to mean that the activity is permissible for FDIC-supervised institutions.
3See Section 3.2, FDIC Risk Management Manual of Examination Policies, at https://www.fdic.gov/regulations/safety/manual/section3-2.pdf
4In addition to the requirements of Section 39 and Part 364, FDIC-supervised institutions engaged in or considering engaging in any crypto-related activities should consider the implications of other relevant statutes and regulations, including, among others, Sections 5 and 6 of the FDI Act, Section 18(a)(4) of the FDI Act, Part 333 of the FDIC’s Rules and Regulations, and Section 8 of the FDI Act.
FIL-16-2022
Attachment(s)
Standards for Safety and Soundness, Section 39 of the Federal Deposit Insurance Act 12 U.S.C. 1831p--1(a), 12 CFR Part 364
Related Topics
Digital Assets
Contact(s)
Division of Risk Management Supervision
Last Updated: April 7, 2022
CONTACT THE FDIC
CONTACT US
STAY INFORMED
Enter your email address
Subscribe
Follow the FDIC on Facebook
Share on X
Follow the FDIC on Instagram
Follow the FDIC on LinkedIn
Follow the FDIC on YouTube
HOW CAN WE HELP YOU? About you
I am a ...
Bank Customer
Banker
Consumer
Small Business Owner
Analyst/Researcher/Student
Legal Professional
Bank Regulator
Press/Media
Vendor/Contractor
Legislative Staff Member
Jobseeker
Court Clerk
Prosecutor/Probation Officer
Investigator
Your request
I want to...
Policies
Help
Foia
En Español
Accessibility
Open Government
usa.gov
Contact Us
Privacy
Plain Writing
No Fear Act Data
Inspector General