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Banking and Cryptocurrency: Custody, Payments, AML, Reporting, Special Purpose Bank Charters

Recording of a 90-minute premium CLE video webinar with Q&A

This program is included with the Strafford CLE Pass. Click for more information.
This program is included with the Strafford All-Access Pass. Click for more information.

Conducted on Tuesday, October 12, 2021

Recorded event now available

or call 1-800-926-7926

This CLE course will examine the legal issues and risks associated with bank adoption of cryptocurrency. The panel will discuss the mechanics of providing custody of digital assets, facilitating payments and reporting of transactions done on blockchain networks, AML and cybersecurity concerns, and the emergence of digital banks operating through limited purpose bank charters.


Recent guidance from the OCC and various state bank regulators expands on the services banks may offer customers relating to cryptocurrencies. In confirming that national banks may provide custody services for digital assets and execute payments using stablecoins, the OCC has encouraged further engagement by banks in cryptocurrency activities. Still, regulatory questions remain.

The process of taking custody of digital assets, including the use of cryptographic access keys to units of cryptocurrency, diverges from typical bank models and poses new risks that must be assessed and managed. The finality of blockchain transactions presents new issues concerning payments.

Banks are required to provide extensive information reporting on assets, customers, and transactions. They will need to enhance their AML, KYC, and BSA compliance programs to meet the challenges of cryptocurrency transactions, including the pseudonymity of many transaction parties on a blockchain.

Listen as our authoritative panel discusses these and other issues associated with cryptocurrency banking. The panel will also discuss the emergence of banks dedicated to digital currencies operating under special purpose bank charters and the ramifications for traditional banks.



  1. Blockchain applications: current state of adoption in the banking industry
  2. Recent OCC guidance on custody and payments: regulatory landscape
  3. Bank operations in the cryptocurrency space
    1. Custody services: cryptographic keys
    2. Payments: executing transactions on a blockchain
  4. Risks and regulatory issues
    1. AML, KYC, and BSA compliance
    2. Reporting issues
    3. Finality of transactions
  5. New banks dedicated to cryptocurrency banking: use of the special purpose charter


The panel will review these and other critical issues:

  • What does custody mean when applied to cryptocurrency, and what are the cybersecurity concerns?
  • How are payments made using cryptocurrency, and what risks are created for banks in executing those payments?
  • How should AML, KYC, and BSA compliance protocols be adjusted to adapt to blockchain technology?
  • What issues still need to be addressed by the OCC and other regulators to facilitate bank engagement in the cryptocurrency space?


Boot, Patrick
Patrick J. Boot

Hunton Andrews Kurth

Mr. Boot is an attorney with the law firm Hunton Andrews Kurth and is based in Austin, Texas. He specializes in...  |  Read More

Levin, Richard B.
Richard B. Levin

Partner; Chair - FinTech and Regulation Practice
Nelson Mullins Riley & Scarborough

Mr. Levin is Chair of the FinTech and Regulation Practice and was one of the first lawyers to focus on the...  |  Read More

Tran, Kevin
Kevin Tran

Of Counsel
Nelson Mullins Riley & Scarborough

Mr. Tran assists clients in matters related to financial regulatory, FinTech, corporate and securities issues. He...  |  Read More

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