The United States is moving forward with the implementation of cryptocurrency trust bank systems, with Circle receiving final approval

The U.S. Office of the Comptroller of the Currency (OCC) has finalized its approval of Circle's "Circle National Trust" on July 10th, marking a concrete step towards establishing a regulatory framework for cryptocurrency companies seeking federal banking charters. Initially, this bank will provide digital asset custody services for Circle and its affiliates, with plans to potentially expand its services to include custody for institutional investors and management of USDC reserves. In addition to Circle, 11 other companies, including Ripple, BitGo, Fidelity Digital Assets, Paxos, Coinbase, Morgan Stanley Digital Trust, Bridge, Crypto.com (Foris DAX), and World Liberty Trust, have received conditional or preliminary approvals from the OCC since 2025. Among these, only Circle has currently obtained final approval, while the remaining companies are working to meet the pre-launch requirements related to capital, governance, and compliance. As of March 31, 2026, the OCC's non-insured national trust banks manage assets totaling $7.2 trillion, with $1.7 trillion held in custody and safekeeping accounts. These institutions are distinct from traditional commercial banks. National trust banks do not accept deposits, issue loans, or offer FDIC deposit insurance. Instead, they focus on acting as custodians, managing tokenized assets, administering stablecoin reserves, and processing payments. The OCC has already supervised approximately 60 national trust banks prior to the emergence of cryptocurrencies, and these cryptocurrency companies are leveraging this established legal framework to isolate and optimize functions specifically tailored for tokenized finance. Controller Jonathan Kan recently stated that out of the 40 new bank charter applications received by the OCC in the past 18 months, 23 include business plans related to digital assets. The OCC also plans to release final regulations related to the GENIUS Act by November. World Liberty Trust is the most recent example, receiving preliminary conditional approval on August 14th. Upon completion, this will integrate the issuance of USD1 and custody of reserves within a single federally regulated entity. A key policy trade-off associated with this structure is the separation of financial functions. By internalizing custody, settlement, and reserve management, cryptocurrency companies can reduce their reliance on intermediary banks, retaining fee income, data, and operational control within the group. However, the accelerated movement of funds into stablecoins could weaken the low-cost deposit base of commercial banks, potentially leading to a reduction in lending capacity. CryptoSlate has previously examined estimates suggesting that stablecoins could absorb billions of dollars in deposits. It is important to note that OCC supervision does not provide the same level of protection as FDIC deposit insurance, and the level of protection depends on the legal structure of the entity holding the assets and the legal treatment of its liabilities.