OCC Crypto Trust Charters: Who Holds One and What It Takes

By Owen Thurm Published November 6, 2026 6 min read

Quick answer. New OCC crypto trust banks need a 12 CFR 30 security program and OCC no-objection to their IT architecture, CISO and CTO. All approvals set tier 1 capital and 180 days of wind-down expenses in liquid assets.

Watch: OCC Crypto Trust Charters: Who Holds One and What It Takes 1:44

Video transcript

New OCC crypto trust banks must show a federal-standard security program and get OCC no-objection to their IT architecture, CISO and CTO.

By September 30, 2026, five crypto-focused trust banks were active. Twelve more held conditional approvals.

They are Anchorage Digital, BitGo, Fidelity, Paxos and Circle's new bank. Ripple, Coinbase and Crypto.com are among those still conditional.

New banks need a program meeting the interagency information security standards, OCC no-objection to their IT architecture and risk plan, an anti-money laundering program, and an independent external audit.

The letters treat the Chief Information Security Officer and Chief Technology Officer as senior executives. The OCC must clear them before appointment.

Tier one capital runs from six to sixty million dollars, set bank by bank. Every approval adds 180 days of wind-down expenses in liquid assets.

Conditions last. Anchorage was approved in 2021 under an operating agreement. A 2022 consent order cited its anti-money laundering program. The order ended in 2025, the agreement in February 2026.

In Guardian's reading, applicants should show an architecture pack, a key standard so no other party moves assets alone, key ceremony drills, a 36 hour incident path and a wind-down plan.

Guardian writes an application's technical sections from the system as built. Read the full guide, or talk to Guardian at guardian.security.

Since December 12, 2025, the OCC has conditionally approved a run of national trust bank charters for digital asset and stablecoin businesses.

By September 30, 2026, five crypto-focused trust banks were on the OCC's list of active national banks.

Each approval carries conditions on capital, liquidity and senior hires, and new banks face IT conditions too. Most run for the first three years and are enforceable under 12 USC 1818.

This guide reads the OCC's decision letters for what an applicant must show.

This article explains the technical and security side of the OCC's national trust bank charter decisions and its chartering rule, 12 CFR 5.20. It is not legal advice; confirm how it applies to you with counsel.

What the Charter Allows

A national trust bank is a national bank limited to "the operations of a trust company and activities related thereto," under 12 USC 27(a). The OCC supervises about 60.

A final rule published March 2, 2026 put that phrase into 12 CFR 5.20. Effective April 1, 2026, it confirms trust banks may conduct non-fiduciary activities, such as custody, as well as fiduciary ones.

Activities in the recent decisions include:

Digital asset custody, mostly in a fiduciary capacity.
Staking, settlement and riskless principal trading for custody clients.
Stablecoin issuance and reserve management, as at Paxos, Bridge and World Liberty.
Collateral trustee services for stablecoin holders, as at Ripple and Bridge.

Each bank must limit itself to trust operations and must not become a "bank" under the Bank Holding Company Act. BitGo's and Paxos's letters say the bank will not take deposits.

Issuers must conform to the GENIUS Act and its rules, as the OCC determines. See our post on the OCC's GENIUS Act final rule.

Who Holds One or Was Approved

Status comes from the OCC's list of national banks active as of September 30, 2026.

Active (5)

Bank	Parent	Approved	Type
Anchorage Digital Bank, N.A.	Anchorage Digital	Jan. 13, 2021	Conversion
BitGo Bank & Trust, N.A.	BitGo	Dec. 12, 2025	Conversion
Fidelity Digital Assets, N.A.	Fidelity (FMR)	Dec. 12, 2025	Conversion
Paxos Trust Company, N.A.	Paxos	Dec. 12, 2025	Conversion
First National Digital Currency Bank, N.A.	Circle	Dec. 12, 2025	New

Conditionally approved (12)

None of these was on the September 30 list.

Bank	Parent	Approved	Type
Ripple National Trust Bank	Ripple	Dec. 12, 2025	New
Bridge National Trust Bank	Bridge (Stripe)	Feb. 12, 2026	New
National Digital Trust Company	Protego	Feb. 13, 2026	New
Foris DAX National Trust Bank	Crypto.com	Feb. 20, 2026	New
Coinbase National Trust Company	Coinbase	Apr. 2, 2026	New
Laser Digital National Trust Bank	Nomura	May 29, 2026	New
Morgan Stanley Digital Trust, N.A.	Morgan Stanley	June 18, 2026	New
Connectia Trust, N.A.	Sony Bank	July 2, 2026	New
World Liberty Trust Company, N.A.	WLTC Holdings	Aug. 14, 2026	New
Agora National Trust Bank	Agora	Sept. 18, 2026	New
Bastion Platforms National Trust Company	Bastion Platforms	Sept. 18, 2026	Conversion
Catena Trust Bank, N.A.	Catena Labs	Sept. 18, 2026	New

Conditional approvals expire. A new bank must raise its capital within 12 months and open within 18 months. A conversion must close within six months unless the OCC extends it.

For how two of the active banks compare as custodians, see BitGo vs Anchorage Digital.

Risk and Security Conditions

The letters repeat a common set of conditions. Here is what they require.

Security and IT (new banks)

A security program that complies with 12 CFR 30, Appendix B, the interagency information security standards.
A complete description of the final IT and operations architecture, with a schematic, for the OCC's written no-objection.
The IT risk assessment and management plan, under the same review.
Board-adopted policies covering all OCC regulations, including a BSA/AML/OFAC program.
An independent external audit, expected annually for at least three years.

People

Before appointing any senior executive officer or director, the bank must notify the OCC and receive a letter of no objection.

The letters count the Chief Information Security Officer and Chief Technology Officer as senior executive officers.

World Liberty's letter adds an independent internal audit manager to oversee its outsourced internal audit.

Capital, liquidity and change

Tier 1 capital minimums are set bank by bank, from $6 million (Bastion) to $60 million (Coinbase's bank and Connectia).
The greater of half that capital or a set amount must sit in Eligible Liquid Assets.
Those are mainly unencumbered cash, deposits at insured banks and US government obligations of 90 days or less.
A further 180 days of operating expenses, sized for a "distressed, wind-down scenario," must also be held in them.
Capital and liquidity must be reassessed every quarter.
Significant business plan changes, including risk limits, need 60 days' notice and OCC no-objection.

What Supervision Looks Like

Anchorage's record shows how long conditions last.

January 2021: its approval came with an operating agreement on capital, liquidity and the OCC's risk management expectations.
April 21, 2022: a consent order found it had not adopted and implemented a BSA/AML compliance program covering the required elements.
August 18, 2025: the OCC terminated the consent order.
February 9, 2026: the OCC ended the operating agreement, finding compliance with all ten actionable articles.

The OCC says it has a supervisory unit for novel banks, staffed by examiners with specialized experience in novel activities.

A Security Program Blueprint

Guardian's reading, not OCC text: what an applicant should be able to hand over.

An architecture pack: systems, key stores, signing paths and data flows, matching production.
An Appendix B program with access controls, dual control, encryption, monitoring and a response plan.
Independent tests of key controls, by third parties or independent staff.
A key standard meeting the July 2025 control test: no other party can move assets alone.
Dated key ceremony, backup and recovery drills.
Due diligence files on sub-custodians, signing vendors and cloud providers.
An incident path that notifies the OCC within 36 hours of determining a notification incident (12 CFR 53.3).
A wind-down plan that matches the 180-day expense reserve.

Our guide to OCC crypto guidance covers the key, custody and sub-custodian controls in detail.

How Guardian Helps

Guardian's institutional practice advises on custody, signing, chains and contract design "while they are still decisions." It writes evidence a risk committee, board or regulator will read.

Guardian's Regulatory Readiness Assessment writes the technical sections of an application "from the system as built."

The OpSec audit covers custody and key ceremony, and Guardian pentests the infrastructure, web apps and APIs around them.

Frequently Asked Questions

Which crypto firms have an OCC national trust charter?

The OCC's September 30, 2026 list of active national banks includes Anchorage Digital Bank, BitGo Bank & Trust, Fidelity Digital Assets, Paxos Trust Company and Circle's First National Digital Currency Bank. Ripple, Coinbase, Crypto.com, Bridge and others were conditionally approved.

Can a national trust bank conduct non-fiduciary activities?

Yes. The OCC's final rule, effective April 1, 2026, amends 12 CFR 5.20 to confirm that national trust banks may conduct non-fiduciary activities, such as custody, alongside fiduciary ones. The OCC decides the source of authority case by case.

How much capital does an OCC crypto trust bank need?

The OCC sets it bank by bank. Tier 1 capital minimums in the decisions we read run from $6 million to $60 million, plus 180 days of wind-down operating expenses held in liquid assets.

How long does a conditional approval last?

A new bank must raise its capital within 12 months and open within 18 months, or the approval expires. A conversion must close within six months unless the OCC grants an extension.

Sources

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