- Key insight: The OCC released three conditional approval decisions for digital asset-focused companies seeking national trust bank charters.
- Expert quote: "All three are trying to bring digital asset and stablecoin-related activities under a federal framework without becoming traditional deposit-taking banks." Javelin's Joel Hugentobler
- Forward look: The conditional approvals bring the firms under the supervision of the OCC ahead of the GENIUS Act taking effect in January 2027.
The Office of the Comptroller of the Currency has issued another batch of national trust charter conditional approvals as digital asset firms anticipate the GENIUS Act's effective date.
The federal agency published three conditional approval decision letters on Friday afternoon, all of which were for national trust bank charters. The recipients – Bastion Platforms, Catena Labs and Agora – are digital asset firms seeking national regulatory supervision for custody ahead of the GENIUS Act's effective date of January 2027.
The batch approval is similar in nature to the OCC's set of five conditional approvals
The approvals are the latest in a
Joel Hugentobler, senior analyst for digital assets and cryptocurrency at Javelin Strategy and Research, told American Banker that he sees a common thread between the recent conditional approvals.
"All three are trying to bring digital asset and stablecoin-related activities under a federal framework without becoming traditional deposit-taking banks," he said.
Bastion, a white-label stablecoin partner for corporations such as
"Before GENIUS came into reality, we were working closely with the regulator that had the most know-how of supervising stablecoin issuance," Bastion CEO Nass Eddequiouaq told American Banker in an interview. "The OCC has caught up very quickly over the last year and a half and is now the forefront of stablecoin [regulation] and GENIUS is in place, which means that you have the same bar across state and federal levels."
The Bastion conversion is largely unaffected by the CLARITY Act, another piece of digital asset legislation
"Stablecoins already got their CLARITY moment," he said. "Everything is already crystal clear. The companies that we're talking to also acknowledge that a sufficient amount of rules are in place for them to take a step into this industry and use stablecoins, and regulators are going to keep providing more guidance over time on any sort of edge case that might arise."
Agora Labs co-founder and CEO Nick van Eck said in a statement that "the charter will bring Agora's stablecoin, custody and transaction infrastructure under direct federal supervision" and "Agora is ready to serve clients with a single entry point to power the modern banking stack."
Agora began issuing its own stablecoin, AUSD, in 2024. Agora's stablecoin issuing entity, Agora Bermuda Limited, is currently headquartered in Bermuda and licensed by the Bermuda Monetary Authority.
After the national trust bank is established, Agora "intends to transition the issuance of AUSD from Agora Bermuda to the bank," according to the firm's decision letter from the OCC.
Neville, who is Catena Labs' CEO, told American Banker in a statement that "AI agents need a new kind of banking platform. Preliminary conditional approval brings us closer to building that institution: one that combines enforceable controls on how agents use money with responsibility for holding and managing customer assets. We see both as essential to making new financial capabilities possible for AI agents safely."
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The three companies' new charters come with different capitalization requirements. Bastion's conversion from New York state to national charter, according to its decision letter, entails $6 million in working capital. Agora and Catena, both of which filed for de novo national trust charter applications, each have a $10 million working capital requirement to get final approval for their trust charters.
"OCC chartering standards don't distinguish between national trust banks and insured national banks," Klaros Group Senior Director Roman Goldstein told American Banker. "In general, national trust banks have lower capital requirements than insured national banks. That does make them somewhat easier to charter. But the lower capital reflects the absence of credit risk: national trust banks don't lend."
Bastion, Agora and Catena Labs initially applied for national trust charters in March, April and May of this year, respectively. The OCC has publicly advertised that it is aiming to turn around decisions on national charter applications to 120 days, even as the agency has
Hugentobler told American Banker that he doesn't see the amount or relative speed of conditional approvals as a sign of lower scrutiny for trust charters, citing the OCC's
"The bigger distinction is the risk profile," he said. "Trust banks generally aren't taking insured deposits or making loans, so they avoid some of the capital, credit and other FDIC-related issues that come with a full-service bank. The barrier may be lower, but the OCC is still scrutinizing management, BSA/AML, governance and the ability to execute the proposed business model."
