The OCC's modernization agenda is accelerating financial innovation; and even as regulatory priorities shift, strong compliance remains essential, because various regulatory expectations and ongoing sanctions will persist
Key insights:
-
-
-
Pushing innovation in the financial sector — The OCC is actively enabling innovation among financial service institutions, not resisting it.
-
-
-
-
-
Regulation is being refocused, not removed — Priorities may change with each administration, but oversight remains, and crypto is increasingly central.
-
Compliance is a growth requirement — Regulations around the BSA, sanctions, and KYC still apply, so durable controls and experienced teams do matter, even with AI.
-
-
Shortly after being named Acting Director of the Comptroller of the Currency in early 2025, Rodney E. Hood set forth priorities for embracing innovation in the financial sector. Hood spoke about improving bank-fintech partnerships and providing regulatory frameworks for digital asset activities.
As expected, the Hon. Jonathan V. Gould was sworn in as the 32nd Comptroller of the Currency on July 15, 2025. Under his leadership of the Office of the Comptroller of the Currency (OCC), the spigot of technology-enabled financial innovation is set to remain wide-open, with blockchain-based products at the forefront.
In his speech to the Blockchain Association, Comptroller Gould laid out a road map to a future that includes more de novo charters, with many of them coming from the ranks of blockchain and digital or virtual asset service providers (VASP). He refuted notions that these things cannot be done under current rules and reaffirmed the agency’s ability to regulate such institutions.
Register now for The 2026 Future of AI and Technology Forum, a cutting-edge conference that will explore the latest advancements in GenAI and their potential to revolutionize compliance, legal, and tax practices
Institutions that fail to embrace these emerging technologies as they arise risk falling behind, Gould said, describing how any legal framework that treats digital assets differently than existing electronic means is risking “a recipe for irrelevance.” Such an antiquated approach keeps companies, institutions, and indeed the nation’s entire financial system, mired in the past, he added.
Digi-mon go!
In word and deed, the current OCC continues to offer a green light to VASPs as well as to traditional financial institutions that are looking to dabble with blockchain, stablecoins, and the like. Regulatory action in the past year mostly served to end prior enforcement against traditional institutions while putting ancillary companies in check. For example, the targeting by the Financial Crimes Enforcement Network (FinCEN) of US/Mexican border casinos, crypto ATM-style terminals, and armored car companies demonstrates the regulatory shift that takes place after each change in administration.
Government rarely gives up its authority, but it does shift the focus. Border cash is out, crypto is in. Clear regulation for this sector is important, necessary, and will continue to create an entirely new set of financial products & services.
Institutions that fail to embrace these emerging technologies as they arise risk falling behind… [and] any legal framework that treats digital assets differently than existing electronic means is risking ‘a recipe for irrelevance.’
Normally I advocate more caution but, in this case, having any regulation is better than having no regulation. Blockchain is here to stay and having any kind of clarity around it is the right way to begin. Those who legislate have an opportunity to improve the regulatory framework over this technology as it evolves — as long as a framework exists. It’s sort of like the slippery slope argument in reverse: When we build a foundation on regulations that encourage innovation while protecting consumers, including the companies themselves, we create a healthier economy. These rules can always be improved and adjusted as we understand better what we have unleashed upon the world.
Compliance is on the “can’t cut” list
Rumors are swirling of cuts to many corporate compliance budgets. Many compliance pros think this administration will let companies do as they please! Let a professional risk manager urge caution here instead. The power of the Bank Secrecy Act (BSA), the extraterritorial reach of sanctions, and the requirements to know your customers (KYC) are not going anywhere. Regulations are refocused, not removed. A proliferation of nouveau financial institutions will provide a target-rich environment for the regulators of today and tomorrow to find things they dislike and prosecute those offenses. A business that hopes to make it big should be built to withstand the winds of change and weather different regulatory conditions over time.
Therefore, smart compliance professionals will keep an eye on the horizon and keep their risk controls tight. Yes, it may be a good time to start a crypto company; but no, that does not mean you can process drug cash, ignore sanctions, or fail to collect basic personally identifying information.
With increasingly ubiquitous AI tools, your humans in the loop are more important than ever. As entry level jobs become automated, depth of experience becomes more valuable. Retain talent and institutional knowledge on your compliance teams because those individuals will train the AI as well as the investigators of tomorrow.
Indeed, no matter who is in charge of the government’s regulations, enforcement will come when you let your guard down and ignore basic risk management principles.
You can find more about how government agencies are managing various risk, fraud, and compliance issues here
