Circle Secures NYDFS Trust Charter Alongside OCC National Bank Approval

Circle, the issuer of the USDC stablecoin, has obtained a trust charter from the New York Department of Financial Services (NYDFS), adding to the federal approval it received earlier in July from the Office of the Comptroller of the Currency (OCC) for First National Digital Currency Bank, which will operate as Circle National Trust. The NYDFS charter replaces the BitLicense under which USDC has been issued, providing stronger legal certainty around protections for stablecoin holders.

Circle’s dual-charter structure mirrors that of Ripple, which issues RLUSD through an NYDFS-regulated trust and holds conditional OCC approval for a national trust charter. In both cases the state trust retains the stablecoin-issuing function and directs the national trust to handle reserve management and custody, though Circle has described reserve management as a future capability rather than something operational at launch. Paxos has taken the opposite path, consolidating into a single structure by converting its NYDFS trust into a national trust.

The commercial logic differs markedly between the two firms pursuing the split model. Ripple’s acquisition of Hidden Road Partners, now part of its prime brokerage offering, gives its national trust a direct external custody client in Ripple Prime, justifying the two-entity structure on standalone commercial grounds. Circle’s national trust is currently limited to providing custody to affiliates, making the rationale for its bifurcated structure more dependent on strategic and legal arguments that remain to be fully articulated.