Circle adds a New York trust charter to USDC's regulatory stack
The NYDFS has granted Circle Internet Trust Company a limited purpose trust charter, putting the USDC issuer under the New York Banking Law a decade after it took the first BitLicense.
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The chartering authority for national banks, whose Interpretive Letter 1183 of 7 March 2025 confirmed cryptoasset custody and certain stablecoin activities as permissible and removed the prior non-objection requirement; it approved Circle's First National Digital Currency Bank on 10 July 2026.
Independent bureau of the US Treasury created by the National Currency Act of 25 February 1863, which charters, regulates and supervises national banks, federal savings associations and the federal branches and agencies of foreign banks, and which receives no appropriations from Congress. Interpretive Letter 1183, issued on 7 March 2025, confirmed that cryptoasset custody, certain stablecoin activities and participation in independent node verification networks are permissible for its institutions, and removed the requirement to obtain supervisory non-objection first; the agency simultaneously withdrew from joint interagency statements on cryptoasset and liquidity risk. Its charter decisions determine which firms may hold stablecoin reserves and tokenized assets under federal rather than state supervision: Anchorage Digital converted in January 2021, BitGo received unconditional approval in December 2025, and Circle's First National Digital Currency Bank was approved on 10 July 2026.
Developments in which Office of the Comptroller of the Currency is a named party, newest first.
The NYDFS has granted Circle Internet Trust Company a limited purpose trust charter, putting the USDC issuer under the New York Banking Law a decade after it took the first BitLicense.
The Office of the Comptroller of the Currency published a proposed rule on 25 February 2026 implementing the GENIUS Act, consolidating reserve, redemption, audit and supervision requirements for payment stablecoin issuers in a new 12 CFR Part 15.
The New York State Department of Financial Services granted Circle Internet Trust Company LLC, trading as Circle New York Trust, a limited purpose trust charter on 31 July 2026, permitting fiduciary, custody and asset-management services under the New York Banking Law. It sits alongside the national trust bank approval the Office of the Comptroller of the Currency gave Circle on 10 July 2026.
The Office of the Comptroller of the Currency published a proposed rule implementing the GENIUS Act, codifying most requirements in a new 12 CFR Part 15 and amending Parts 3, 6, 8 and 19. The proposal covers permitted activities, reserve assets, redemption, risk management, audits, reports and supervision for permitted payment stablecoin issuers, and applies to national banks, federal savings associations, federal branches and agencies, foreign issuers and non-bank applicants for federal issuer approval.
In Interpretive Letter 1184 the Office of the Comptroller of the Currency confirmed that national banks and federal savings associations may hold crypto-assets in custody and buy and sell assets held in custody at a customer's direction. The letter also stated that banks may outsource bank-permissible crypto-asset custody and execution activities to third parties subject to third-party risk management, and built on the earlier Interpretive Letters 1170 and 1183.
The President's Working Group on Financial Markets, with the FDIC and the OCC, recommended that Congress require stablecoin issuers to be insured depository institutions, subject custodial wallet providers to federal oversight, limit issuers' affiliation with commercial entities and promote interoperability between stablecoins. Treasury Secretary Janet Yellen said existing oversight was inconsistent and fragmented, and agencies committed to acting within current authority while legislation was pending.
The Office of the Comptroller of the Currency conditionally approved the conversion of Anchorage Trust Company, a South Dakota chartered trust company, into Anchorage Digital Bank, National Association, subject to an operating agreement setting capital, liquidity and risk management expectations. The charter created a federally supervised entity able to act as custodian and, later, as issuer of record for regulated dollar tokens.
The Office of the Comptroller of the Currency issued Interpretive Letter 1174, confirming that federally chartered banks and thrifts may participate in independent node verification networks and use stablecoins for payment activities, validating, storing and recording transactions. Acting Comptroller Brian Brooks said the letter "removes any legal uncertainty about the authority of banks to connect to blockchains as validator nodes and thereby transact stablecoin payments", subject to Bank Secrecy Act programmes tailored to those risks.
The Office of the Comptroller of the Currency published Interpretive Letter 1172, stating that national banks and federal savings associations may hold reserves on behalf of customers who issue stablecoins backed one-for-one by a single fiat currency in hosted wallets, with daily verification that reserve balances match tokens outstanding. Acting Comptroller Brian Brooks said banks were already handling such activity involving billions of dollars each day and the letter was meant to provide regulatory certainty.
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