OCC Grants Conditional Approval to Crypto Firms for National Trust Bank Charters

On December 12, 2025, the U.S. Office of the Comptroller of the Currency (OCC) announced that it has granted conditional approval for several prominent cryptocurrency firms—including Ripple, BitGo, Paxos and Circle (together, “the Companies”)—to establish national trust banks. This development marks a significant regulatory milestone for the digital asset industry, with the potential to reshape the landscape for crypto-related financial services in the United States.

OCC Conditional Approvals

The OCC’s decision granted conditional approval to the Companies to establish national trust banks, subject to meeting certain requirements before commencing full operations. This is the first time the OCC has granted such approvals to multiple crypto-native firms simultaneously. However, it is important to note that the OCC’s conditional approvals are not final charters. Each firm must satisfy additional regulatory and operational requirements, including compliance with anti-money laundering (AML) and know-your-customer (KYC) obligations, before they can fully launch as national trust banks.

Regulatory Context

The OCC’s actions in providing conditional approval for national trust bank establishment are part of an ongoing effort to provide regulatory clarity and oversight for digital asset firms seeking to operate at a national level. The conditional approvals follow a period of public consultation and engagement with industry stakeholders, though the OCC has not published the full list of comments or its responses. The OCC specified in its news release that the agency will continue to supervise these entities for safety, soundness and compliance with applicable law.

Implications for the Digital Asset Industry

The OCC’s conditional approvals provide a clearer pathway for crypto firms to access the U.S. banking system, which could facilitate broader adoption of digital asset services while also subjecting crypto firms to federal oversight. This may enhance consumer confidence and standardize compliance practices. Other digital asset firms, including Coinbase, Bridge (owned by Stripe), and Crypto.com have also applied to become federally chartered banks.

The approvals are not final, and each firm must meet additional requirements before commencing operations. The OCC has not published a comprehensive list of these conditions. No definitive timeline has been provided for when the approved firms will meet the OCC’s requirements and begin offering trust bank services. The OCC has indicated that it will maintain rigorous supervision of these entities, but specific supervisory protocols have not been disclosed.

Considerations for Stakeholders

Banks, other financial institutions, and other interested parties should proactively monitor the evolving regulatory landscape, as the entry of crypto-native trust banks may impact competition and partnership opportunities in digital asset custody and settlement. Digital asset businesses, considering similar national trust bank charters should closely review the OCC’s conditions and ongoing compliance expectations. Similarly, prospective clients of these new potential trust banks should remain attentive to further announcements regarding the scope of services, operational timelines, and consumer protections.

Conclusion

The OCC’s conditional approval for the Companies to establish national trust banks represents a significant step in the integration of digital asset firms into the U.S. financial system. However, the approvals are subject to substantial, yet unspecified, conditions and requirements. Stakeholders should stay vigilant for further updates as these firms work toward meeting the OCC’s requirements and launching their national trust bank operations.

For more information or to discuss how these developments may affect your organization, please contact the Buchanan Blockchain Digital Asset Group.