Circle OCC approval: trust bank opens without reserve control

Circle secured final approval from the Office of the Comptroller of the Currency on Friday to open Circle National Trust, giving the USDC issuer a national trust bank as more than $73 billion of USDC sits under scrutiny from regulators and institutional users. At launch, the charter covers fiduciary custody for digital assets, not direct control of the stablecoin’s reserves.

In its statement, Circle said First National Digital Currency Bank, N.A. will do business as Circle National Trust, begin with custody services and add reserve management only in a later phase. The Block reported that the missing reserve function is the main limit on the charter at launch. The same report said the approval does not allow cash deposits or loans, leaving Circle with a custody bank rather than a full commercial bank.

Jeremy Allaire, Circle’s co-founder, chairman and chief executive, framed the approval as a governance win.

“Federal oversight of our trust bank sets a new standard for transparency, governance, and scale.”
— Jeremy Allaire, Circle

The distinction matters because custody is only one piece of the stablecoin stack. A national trust bank gives Circle a single federally supervised entity to present to partners assessing custody, compliance and fiduciary controls. It does not yet give the company direct command of the cash and short-dated Treasury assets that underpin USDC.

Circle filed its OCC application on June 30, 2025, and moved into conditional approval in December 2025, according to Circle’s release and The Block’s reporting. The decision puts Circle alongside a small group of crypto-linked firms that have sought federal trust status since Anchorage Digital Bank became the first crypto company to win a national trust charter in 2021. The sequence shows that the OCC is willing to approve limited crypto-bank structures while phasing in powers rather than handing over the full operating stack at once.

Why the charter matters

A trust charter should let Circle pull more custody work under one supervisor and reduce reliance on outside banks and custodians. CNBC reported that the company had previously relied on third-party banks and custodians for some regulated functions. For institutional clients, that kind of chain-of-control story can matter as much as yield or trading volume because a digital dollar is only as credible as the assets and legal structure behind it.

Reserve management remains the larger prize. Control over the reserve portfolio would give Circle more say over counterparties, custody arrangements and disclosure around the assets backing USDC. Circle’s own wording says that step comes later. Until then, the company can say it has moved closer to the banking perimeter, but not that it runs the reserve base from inside its own bank.

The approval also lands in the middle of a wider charter race. Sony Bank won conditional OCC approval one day earlier for a US trust structure tied to stablecoin issuance, and The Block said Circle’s path sits alongside applications or approvals involving other crypto and payments groups. Sony’s case shows the charter route is not limited to crypto-native issuers. It is becoming an option for banks and payments groups that want a compliant dollar-token footprint in the US without becoming deposit-funded lenders.

That makes Friday’s sign-off matter beyond one company’s charter file. If the OCC keeps approving narrowly tailored trust banks, stablecoin issuers, exchange groups and foreign entrants will have a clearer federal path to custody and issuance before Washington finishes writing the broader rules for digital-dollar competition.

CNBC said Circle shares rose 12 per cent after the news. The more durable signal may be the model the OCC is endorsing: phased authority, custody first, and reserve control only after a regulator is satisfied with governance and supervision.