Basel Committee on Banking Supervision, Basel Committee, FTX, Silvergate, Board of Governors of the Federal Reserve System, Federal Reserve, Federal Deposit Insurance Corporation, FDIC, Office of the Comptroller of the Currency, OCC


This Article summarizes the limited publicly available data on banks’ exposure to crypto assets and offers several specific examples of how U.S. banks engage in crypto-related businesses. It then examines past guidance issued by U.S. bank regulators and explains why this guidance lacks sufficient detail to clarify the prudential requirements associated with the various crypto-related activities in which banks are engaged. The Article then assesses the adequacy of the Basel Committee on Banking Supervision’s final prudential standard for crypto-asset exposures, issued in December 2022, and finds that the measure fails to adequately address the unique risks various crypto-asset activities pose to banks. We conclude by offering recommendations U.S. bank regulators can quickly implement to dimension the scale of banks’ crypto-asset exposure and mitigate the associated risks.