FDIC Guidance on Crypto

On Demand Course

Instructor: Kathy Tomasofsky, Michelle Gitlitz

Duration: 1 HR

What You'll Learn

Learn how recent FDIC guidance enables banks to engage in crypto-related activities. This presentation will provide attendees with the practical implications of and a better understanding how to execute on the FDIC’s new guidance. By reviewing the timeline of regulatory developments and future directions, institutions can anticipate compliance needs and position themselves strategically. Additionally, the guidance reinforces safety and soundness principles, helping banks maintain strong risk management practices while preparing for future regulatory changes.

Topics covered in this session

Overview of FDIC’s Financial Institution Letter (FIL-7-2025) dated March 28, 2025 that provides new guidance for FDIC-supervised institutions engaging or seeking to engage in crypto-related activities.

Key changes from previous regulatory guidance
Comparison to OCC’s similar reversal of prior guidance
Timeline of regulatory developments and future directions

Currently Permissible Crypto-Related Activities for Banks

Crypto-asset custody services
Stablecoin reserve management and issuance
Blockchain-based settlement and payment systems
Node operation on permissioned blockchains
Market-making and exchange services
Limits and boundaries of permissible activities

Regulatory Expectations and Compliance Fundamentals

Safety and soundness principles in crypto context
Ongoing supervisory expectations
Preparing for future guidance and regulations

*This program does NOT qualify, nor meet the National Standard for NASBA accreditation

About the Author:

Kathy Tomasofsky, Michelle Gitlitz

Kathy Tomasofsky is the Executive Director of the Money Services Business Association (MSBA), a national trade association focused on money transmission payments and products. The association was launched in October 2015 as a voice for the Money Service Businesses with a focus on licensed entities. In her role as Executive Director, she provides Strategic guidance to the Board and works closely with State and Federal Regulators on behalf of the membership. She is an experienced management and operations professional with more than 30 years’ experience in Insurance and Financial Services. Ms. Tomasofsky has held various senior management level positions at the Network Branded Prepaid Card Association, USF&G Insurance and First National Bank of Maryland and was an Advisory Board Member to the IAFCI. Ms. Tomasofsky earned an MS in Management Information Systems from the University of Baltimore and a BA in Business Administration from Loyola College in Maryland. She holds an MAT degree from Fairleigh Dickinson College, in New Jersey and has certifications in Project Management and Insurance.

Michelle Ann Gitlitz is co-founder and CEO of Change Agents Technologies Inc., a software company focused on financial regulatory compliance. Ms. Gitlitz has significant experience in evaluating regulatory issues for digital asset, cryptocurrency, decentralized finance and tradititional payment system providers. She has designed and reviewed state and federal money transmission, banking, cybersecurity, privacy and compliance programs for market participants. Ms. Gitlitz previously served as general counsel and corporate secretary of a FinCEN-registered and state regulated digital asset money transmitter from October 2021 through December 2023. Prior to that, Ms. Gitlitz was the co-head of the financial services practice group and head of the blockchain and digital asset practice group at two AmLaw 100 law firms. She is the author of Reimagining Payments: The Business Case for Digital Currencies (Racket Publishing 2023) and an adjunct professor at the University of Miami School of Law teaching a course on digital commerce regulation. At the recommendation of New York Attorney General Letitia James, Ms. Gitlitz was appointed by Judge Andrew Borrok of New York Supreme Court as the receiver for the defunct crypto platform.

On-Demand Course