Circle Internet Group received conditional approval from the Office of the Comptroller of the Currency on December 12, 2025, to establish First National Digital Currency Bank, a national trust bank that would manage the USDC stablecoin reserve and provide custody services to institutional customers.
The conditional approval represents a key milestone toward compliance with the GENIUS Act, federal legislation that became law in July 2025 and establishes regulatory requirements for U.S. stablecoin issuers. Once fully approved, the trust bank would operate as a federally regulated institution subject to OCC oversight, strengthening the infrastructure supporting USDC, the world’s largest regulated stablecoin.
Circle submitted its application to the OCC on June 30, 2025, nearly six months before receiving conditional approval. The company said the trust bank charter would enhance the safety and regulatory oversight of the USDC Reserve while enabling it to offer fiduciary digital asset custody and related services to institutional customers.
The OCC announcement on December 12 marked the first time the regulator had granted multiple crypto-native firms conditional charter approvals simultaneously. In addition to Circle, the OCC conditionally approved applications from Ripple, Paxos, BitGo, and Fidelity Digital Assets to establish national trust banks. The batch approval signaled a broader regulatory push to bring digital asset firms under federal banking oversight as stablecoins and blockchain technology move into mainstream finance.
Circle has pursued regulatory pathways across jurisdictions globally. In 2015, Circle became the first company to receive a BitLicense from the New York Department of Financial Services. In 2024, Circle became the first global stablecoin issuer to comply with the European Union’s Markets in Crypto-Assets regulatory framework. The company holds e-money and payments licenses in the UK, Singapore, and Bermuda, and received approval from Abu Dhabi Global Market’s Financial Services Regulatory Authority to operate as a money services provider in 2025.
Sources
- Circle Investor Relations — conditional approval announcement and details on USDC Reserve management, GENIUS Act compliance, and Circle’s regulatory history
- Office of the Comptroller of the Currency — December 12, 2025 announcement of five conditional approvals for national trust bank charters
- Banking Dive — reporting on the five-firm conditional approval batch
- CoinDesk — coverage of the OCC’s conditional approval decision and the five firms approved
