Key Takeaways
- The OCC’s updated policy allows national banks and federal savings associations to engage in select cryptocurrency activities, provided they adhere to robust risk management frameworks.
- This regulatory shift paves the way for banks to explore new digital asset services, including stablecoin issuance and tokenized deposits, enhancing liquidity management and capital efficiency.
- Rimark’s Solstice Protocol and deposit token strategy align seamlessly with the OCC’s new guidelines, offering a secure and compliant platform for banks entering the digital assets market, with a focus on quantum resilience and end-to-end cryptographic attestation.
Understanding the OCC Policy Update
The U.S. Office of the Comptroller of the Currency (OCC) has introduced a significant policy update that allows national banks and federal savings associations to participate in select cryptocurrency activities (OCC, 2025). This regulatory shift enables financial institutions to integrate digital assets into their service offerings, provided they implement a robust risk management framework incorporating comprehensive governance, stringent anti-money laundering (AML) and counter-terrorism financing (CTF) protocols, and advanced fraud detection mechanisms.
The OCC’s policy highlights the need for operational resilience and reinforces the importance of maintaining a strong internal control environment, particularly in the areas of custody, settlement, and liquidity management. The guidance also emphasizes the application of advanced cryptographic methods, risk-based due diligence, and adherence to the Basel Committee on Banking Supervision’s (BCBS) principles for managing digital asset exposures.
One of the most promising opportunities this policy unlocks is the ability for banks to issue deposit tokens, a new form of digital asset that bridges the gap between traditional finance and blockchain technology.
What Are Deposit Tokens?
Deposit tokens are a form of digital asset that represent a claim on underlying fiat currency held at a financial institution. These tokens operate as on-chain liabilities of the issuing bank and are fully backed by corresponding fiat deposits, enabling a transparent and auditable connection between digital and traditional financial systems. Unlike stablecoins, which are often issued by non-bank entities and may not offer the same level of regulatory oversight or transparency, deposit tokens provide a compliant and secure mechanism for executing digital transactions.
Deposit tokens facilitate programmable money use cases, allowing for atomic settlement in real-time, automated liquidity provisioning, and improved treasury management through smart contract-driven conditional transactions. They are well-suited for use in cross-border remittances, wholesale banking operations, interbank liquidity facilities, and corporate treasury management, where speed, security, and compliance are paramount.
How Solstice Protocol Supports Deposit Tokens
Rimark’s Solstice Protocol employs a hybrid architecture combining Solstice Core and Solstice Network to create a fully automated, cryptographically attested reconciliation model for deposit tokens. Solstice Core functions as the on-premise, air-gapped internal system that banks use for transaction initiation, processing, and cryptographic signing. This ensures quantum-resilient security, real-time transaction throughput, and compliance with financial data sovereignty requirements.
Solstice Network serves as the decentralized settlement layer, handling external financial transactions, liquidity management, and global reconciliation through a permissioned blockchain network. When a bank issues a deposit token via Solstice Core, the transaction undergoes a multi-layered cryptographic process. It is signed with ML-DSA (Dilithium) for digital authentication, encrypted using ML-KEM (Kyber) for quantum-safe confidentiality, and transferred to the Solstice Network using a secure data diode or TEE node.
Solstice Neural Net: AI-Driven Liquidity Management
The Solstice Neural Net (SNN) is a proprietary machine learning (ML) model built on Google Cloud Platform’s Vertex AI, designed to optimize liquidity management, capital deployment, and portfolio rebalancing through AI-driven methodologies. The SNN plays a crucial role in maximizing liquidity management within the regulatory framework established by the OCC's updated policy.
SNN operates through a dynamic capital allocation model, integrating real-time market analytics, macroeconomic risk assessment, and transaction velocity across the Solstice Network. It automates capital allocation across traditional money market instruments, U.S. Treasuries, repo markets, and alternative risk-weighted assets, including tokenized RWAs and private market instruments.
The phased strategy of SNN enhances liquidity management by combining a dual-layer hedging approach with smart contract governance. This integration with Solstice Core and Solstice Network enables tokenized deposits to be managed with advanced risk controls, aligning with the OCC’s emphasis on sound governance and robust risk management.
Enabling Banks as Node Validators and Unlocking New Revenue Streams
The updated OCC policy not only allows banks to engage in digital asset activities but also provides them the opportunity to act as node validators within blockchain networks. Rimark's Solstice Protocol supports this model by enabling its customer banks to participate as node validators on both the Solstice Network and public blockchains such as Solana.
By acting as node validators, banks can contribute to network consensus, validate transactions, and earn staking rewards or transaction fees. These activities generate new, non-interest income streams for banks, complementing traditional fee-based services. Furthermore, banks can offer custody services for digital assets, provide liquidity to decentralized finance (DeFi) platforms, and facilitate digital asset lending, all of which are enabled by the infrastructure provided by Solstice Protocol.
Why Banks Need Both Permissioned DLT and Public Blockchain Capabilities
To fully capitalize on the opportunities presented by the OCC’s updated policy, banks should adopt a hybrid approach that utilizes both permissioned DLT for internal ledgering and the issuance of deposit tokens on public blockchains. Permissioned DLT systems, like Solstice Core, provide banks with enhanced control, security, and compliance for internal processes. This setup ensures real-time reconciliation, secure internal record-keeping, and adherence to stringent regulatory requirements.
Conversely, issuing deposit tokens on a public blockchain such as Solana offers banks access to increased liquidity, broader market reach, and participation in decentralized finance ecosystems. Public blockchains support transparency, interoperability, and the ability to offer innovative services such as tokenized deposits, cross-border payments, and digital asset custody.
By combining both approaches, banks can maintain a secure and compliant internal environment while leveraging the benefits of public blockchain networks for customer-facing financial products. This hybrid strategy not only enhances operational security and compliance but also allows banks to remain competitive in a rapidly evolving financial landscape.
Summary
The OCC’s updated policy establishes a comprehensive regulatory framework that allows national banks and federal savings associations to participate in a broad spectrum of digital asset activities. These activities include issuing deposit tokens, facilitating stablecoin transactions, and acting as node validators on blockchain networks. This regulatory clarity enables financial institutions to integrate advanced digital asset strategies into their offerings, from digital payment solutions and tokenized securities to decentralized finance (DeFi) participation and blockchain infrastructure management. Rimark’s Solstice Protocol, enhanced by the AI-driven liquidity management of Solstice Neural Net, delivers a robust, quantum-resilient platform that supports compliance, operational security, and financial efficiency across these diverse digital asset activities.
Through its integration of Solstice Core and Solstice Network, Rimark enables real-time transaction settlement, advanced cryptographic security, and the ability for banks to act as node validators on both private and public blockchains. By unlocking new revenue streams through transaction fees, staking rewards, and digital asset services, banks adopting innovative technologies like Solstice Protocol are likely to gain a significant competitive advantage in the evolving financial landscape.
Contact Rimark today to learn more about how the Solstice Protocol can support your bank’s digital asset initiatives.
References
Forbes. (2025). Banks In Crypto: The OCC's Quiet Game-Changer. [online] Available at:
https://www.forbes.com/sites/digital-assets/2025/03/09/banks-in-crypto-the-occs-quiet-game-changer/
OCC. (2025). OCC Updates Policy on Bank Cryptocurrency Activities. U.S. Office of the Comptroller of the Currency. [online] Available at:
https://www.occ.treas.gov/news-issuances/news-releases/2025/nr-occ-2025-16.html
Rimark. (2025). Eliminating Counterparty Risk with Private DLT. [online] Available at:
https://www.rimark.io/post/eliminating-counterparty-risk-with-private-dlt
