On 10 July 2026, the U.S. Office of the Comptroller of the Currency issued its final approval for Circle Internet Group to establish Circle National Trust Bank under the National Bank Act. Circle applied for the national trust charter in June 2025; the OCC granted conditional approval in December 2025 and converted it to a final charter on 10 July 2026. The bank operates as a federally chartered trust institution subject to ongoing OCC examination, capital standards, and conduct requirements.
The National Bank Act, 12 U.S.C. §§ 1 et seq., is the primary chartering authority, supplemented by OCC fiduciary regulations at 12 C.F.R. Part 9 and general corporate activity rules at 12 C.F.R. Part 7. OCC Interpretive Letter 1179 (November 2021) confirmed that national banks may provide cryptocurrency custody as a permissible trust activity, and Circle National Trust Bank's charter operates within that established authority. A national trust bank is limited to fiduciary and custody functions and may not accept demand deposits or make commercial loans.
Stablecoin issuers, institutional custodians, digital-asset funds, and corporate treasury desks gain a federally chartered OCC-supervised counterparty for three previously fragmented services: USDC reserve management, fiduciary digital-asset custody, and direct institutional custody. Institutional investors whose governing mandates require a nationally chartered custodian before allocating to digital assets now have a qualifying entity. Payment-service providers and exchanges routing USDC in settlement flows can direct reserves through a federally regulated vehicle subject to OCC oversight.
The national trust charter does not convert Circle into a full commercial bank: demand-deposit-taking and commercial lending remain outside the permitted scope. Federal preemption of state money-transmitter licensing applies only to functions covered by the trust charter, leaving Circle's other state-level obligations intact. Circle's reserve composition, attestation, and disclosure obligations as a payment stablecoin issuer under applicable U.S. federal stablecoin statutes and OCC guidance apply independently and are not satisfied by the national trust charter.
Licentium advises on stablecoin regulatory strategy, digital-asset custody licensing, and U.S. federal banking charter applications. If your organisation is assessing the operational or compliance implications of the OCC's approval for Circle National Trust Bank, we can assist directly or through our partner network. Work we undertake includes crypto regulatory licensing, stablecoin legal advisory, digital-asset custody compliance, and national bank charter strategy.