#加密资产交易风险管理 The core logic of OCC Interpretation Letter No. 1188 is quite clear: risk-free principal trading, modern custody models, and the positioning of trust charters—essentially delineating a clear scope of application for crypto asset activities within the existing regulatory framework.

From an on-chain perspective, what does this mean? Once licensed US banks begin explicitly participating in crypto transactions, a traceable new pattern of institutional fund inflows and outflows will emerge. Under the risk-free principal structure, banks act only as intermediaries rather than holding positions, which on-chain manifests as rapid fund circulation and quick position hedging and liquidation. The slow-building trading style of large exchange traders will be completely replaced by a much faster rhythm.

It is worth paying attention to the path of licensed trust banks. If crypto companies obtain a national trust license regulated by OCC, the roles of stablecoin reserves, large-scale custody, and settlement hubs will shift. This not only changes the geographic distribution of fund flows but also alters the certainty of large on-chain transfers—funds coming in and out from federally regulated entities have completely different risk characteristics and market expectations.

In the short term, this is a major upgrade in risk management. In the long term, it determines who will build the core infrastructure for US crypto custody and trading over the next five years. Gould’s rejection of BPI’s unified veto means that true filtering will occur through case-by-case review—business models, risk control systems, and ownership transparency are the real levers.

The key lies in execution speed. How quickly this interpretation can be translated into actual licensed entities and on-chain fund flows will determine the pace of market structure changes.