Circle Wins Full OCC National Trust Bank Charter, First Among Peers

Circle has received final approval from the Office of the Comptroller of the Currency (OCC) for First National Digital Currency Bank, which will operate as Circle National Trust. The conditional approval granted in December has now converted into a full charter, making Circle the first among a cohort of five firms to reach that milestone. Coinbase received a preliminary approval in April, while Ripple, Paxos, BitGo, and Fidelity Digital Assets remain at the conditional stage.

At launch, Circle National Trust will perform a single function: digital asset custody for Circle and its affiliates. Managing the USDC reserve is described as a planned future capability. The approved business plan also indicates that the bank may eventually extend its custody service to a limited number of institutional clients, with a stated focus on banks, other financial institutions, and regulated derivatives organisations.

The charter does not authorise USDC issuance. Circle has separately applied to the New York Department of Financial Services (NYDFS) for a limited purpose trust company, and plans to shift USDC issuance to that entity once established. The resulting structure places stablecoin issuance under state regulation while a federally chartered bank holds the backing assets. This two-layer architecture mirrors Ripple’s approach with RLUSD, which is issued through a New York trust company while Ripple simultaneously pursues a national trust charter to manage its reserves. Paxos and BitGo have taken the opposite path, converting their New York charters into federal ones, illustrating that no single structural template has emerged as the industry standard.