Banking on Blockchain - September 2025 Edition
Welcome to Banking on Blockchain — your monthly source for strategic insights, product innovation, and proof points from the institutions shaping the future of finance.
Regulation & Risk: The Starting Point
Banks entering digital assets must begin with the non-negotiables — regulation and risk management. This month’s update is dedicated to those pillars.
The GENIUS Act is a watershed moment, granting banks (through approved entities) the ability to issue payment stablecoins directly. It also sets an ambitious timeline for rules covering reserves, fiat on/off-ramps, custody, and more — establishing the regulatory scaffolding that will define the market.
In the U.S., custody requirements are catching up with what banks already master, a trend mirrored globally. The OCC’s Interpretive Letter 1184 confirms the path is open—while raising the bar on governance and oversight.
Globally, this trend is mirrored: regulators are pressing participants to lead with prudential standards and risk controls as they expand into digital money. The direction is clear— firms that embed regulation and risk at the foundation will be best placed to scale digital asset businesses safely and credibly.
📍 Want to go deeper? Meet Fireblocks’ Chief Strategy Officer Stephen Richardson , Chief Legal & Compliance Officer Jason P. Allegrante , and our Banking Solutions team at Sibos, Stand DISL68X.
New to Fireblocks? Here’s what we do.
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Our Client
Each month, we’re spotlighting a leading institution building a real-world business on Fireblocks.
This month: The State of Wyoming, the first U.S. state to issue a fiat-backed stable token chose Fireblocks to launch FRNT across seven blockchains.
Thought Leadership
Insights from global leaders and regulators—curated for banks and FMIs.
U.S. Crypto Custody Rules: What’s Next?
Jason P. Allegrante , our Chief Legal and Compliance Officer, breaks down the latest report from the White House Working Group, which signals a clear shift from policy discussion to regulatory implementation. The focus is now on concrete issues like self-custody, qualified custodians, and alignment with NIST cybersecurity standards. For institutions still waiting on definitive guidance, this report offers a critical turning point that may unlock broader adoption. Read the blog post here.
What OCC Letter 1184 Means for Banks Getting Into Crypto
Interpretive Letter 1184 confirms that national banks can offer crypto custody services without prior supervisory approval, provided they meet the usual expectations for safety and soundness. Peter M. our Director of Digital Identity & US Policy, outlines the operational impacts of this shift, including how banks should approach third-party risk, cybersecurity, and product governance when entering crypto markets. It is a green light that still comes with conditions. Read the blog post here.
What’s Next for Banks Entering Crypto? Navigating The Risks
Peter M. expands on how the dual banking system and state-by-state divergence have made it harder for institutions to navigate crypto-related risks. While federal progress has picked up speed, the regulatory environment remains complex. This piece gives banks a map for navigating third-party vendors, operational risk, and compliance expectations in a rapidly maturing ecosystem. Aligning internal frameworks with this evolving playbook is no longer optional. Read the blog post here.
New Feature: Cyber Operational and Resilience (COR) Compliance Package for DORA
Our Cyber & Operational Resilience (COR) Package streamlines regulatory compliance by aligning with EU’s Digital Operational Resilience Act (DORA), including reporting, audit and pen testing support. Our solution delivers periodic reports, event notifications, and tools to simplify compliance obligations, allowing customers insights into our processes, while reducing operational and cyber risks.
Where to Find Us
We partner with 70+ banks worldwide, delivering custody, settlement, tokenization, and payments infrastructure at bank scale. Let’s connect.
Upcoming Webinars:
Sept 18: Winning the Stablecoin Race with Fireblock's Ana Santillan Nieto
Sept 18: Are Stablecoins the future of Finance in APAC with Fireblock's Amy Zhang
Upcoming Events:
Sibos 2025 (Frankfurt, September) - Meet with us onsite at stand DISL68
Token2049 (Singapore, October) Meet with us at onsite at Level 5 - Booth # PB5-87/90
We’re also collecting feedback: what do you want to see more (or less) of in this newsletter? →Tell us in the comments.
Fireblocks powers over 70 banks globally with a unified platform for asset issuance (tokenization), custody, settlement, and digital asset lifecycle management. We connect institutions to the broader ecosystem while delivering the security and control internal policies and regulators demand. Built for flexibility and scale, our modular infrastructure supports both MPC and HSM, with a “single pane of glass” experience that mirrors the resilience of core banking systems. We have an API-first architecture and a follow-the-sun support model. We serve over 2400+ clients globally.
Great share and 100% aligned with the direction 👏👏@fireblocks, @michael shaulov