Circle Makes a Play for National Trust Bank License — What’s at Stake?

Following its IPO ambitions, stablecoin issuer Circle has confirmed it has applied to the U.S. Office of the Comptroller of the Currency (OCC) for a National Trust Bank Charter. The move could pave the way for Circle to establish the First National Digital Currency Bank, offering digital asset custody services under direct federal oversight — a significant step toward integrating stablecoins into the regulated banking ecosystem.

What Is the OCC’s National Trust Bank Charter?

The National Trust Bank Charter, granted by the OCC, allows companies to operate at the federal level and provide specialized financial services — especially those centered around digital assets. Key permissions include:

• Digital Asset Custody: The right to legally custody cryptocurrencies, stablecoins, and tokenized assets.
• Trust Services: Offering asset management and services such as estate planning or pension fund administration for institutional clients.
• No Traditional Banking: Activities like deposit-taking or loan issuance are generally outside the scope of this charter.
• Federal Supervision: License holders are overseen by the OCC, avoiding the need for state-by-state licenses — creating regulatory consistency and bolstering market confidence.

According to OCC guidelines, Circle’s application, submitted on June 30, will go through a 30-day public comment period before the regulator decides within 120 days.

Why This Matters for Circle — and the Industry

Currently, Circle relies on custodians like BNY Mellon and BlackRock to manage its USDC reserves. With the OCC license, Circle could directly oversee its own reserves, offer custody services to institutional clients, and potentially integrate its stablecoin more deeply into traditional financial infrastructure.

A federal license would also cement Circle’s status in the U.S., granting it a seat at the table in international regulatory discussions and enabling it to push for greater global regulatory alignment on stablecoins.

A Rare Approval — Can Circle Be the Second?

So far, Anchorage Digital is the only crypto company to have secured an OCC National Trust Bank license during the Biden administration (albeit a conditional approval). Other companies, like Fidelity Digital Assets, are reportedly pursuing the same license, but the regulatory bar is high.

For example, Paxos received conditional approval in 2021 for Paxos National Trust, but after a series of events, it failed to secure full authorization. OCC records show that Paxos’ bank charter application expired in March 2023.

A Broader Strategy at Play?

Circle’s efforts to secure a trust bank license could also revive its ambitions for broader access to Federal Reserve operations, such as entering the Fed’s reverse repurchase agreements (RRP) market — an idea once floated via its Circle Reserve Fund managed by BlackRock. As some analysts point out, Circle’s strategy might be seen as a silent but potent challenge to the traditional financial system — leveraging regulatory opportunities to embed stablecoins deeper into mainstream finance.

Whether Circle’s move will redefine the stablecoin landscape — or become another stalled attempt like Paxos — will likely shape how regulators, investors, and institutions view the future of dollar-based stablecoins in the United States.

Risk Warning
Cryptocurrency investments are highly volatile and may lead to total loss of capital. Always conduct your own risk assessment before investing.