Circle seeks OCC approval for First National Digital Currency Bank, N.A. – federal status, custodial functions, and a new level of institutional compatibility for USDC.
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First National Digital Currency Bank, N.A. – federal status and custodial functions for Circle
An important step in strengthening Circle’s strategic position in the stablecoin market: the company is seeking a federal trust bank license in the United States – First National Digital Currency Bank, N.A. The decision lies with the Office of the Comptroller of the Currency, which will also oversee compliance and exercise regulatory supervision.
If granted, the license would open up a completely different level of operational capabilities for Circle, starting with the legal status itself and potentially eliminating the need to rely on banking counterparties. A comparable move was recently made by European regulators, albeit on a broader scale – namely, the ECB opens TIPS and TARGET2 access to fintechs. Another fundamentally important opportunity would be that the bank structure enables Circle to offer custodial services to institutional clients.
In addition, Circle emphasizes that this step would help the company achieve better alignment with the GENIUS Act – an initiative nearing final approval, which holds critical significance for stablecoins and possibly the broader U.S. economy.
Circle Co-Founder, Chairman, and CEO Jeremy Allaire said:
“Establishing a national digital currency trust bank of this kind marks a significant milestone in our goal to build an internet financial system that is transparent, efficient, and accessible. By applying for a national trust charter, Circle is taking proactive steps to further strengthen our USDC infrastructure. Further, we will align with emerging U.S. regulation for the issuance and operation of dollar-denominated payment stablecoins, which we believe can enhance the reach and resilience of the U.S. dollar, and support the development of crucial, market-neutral infrastructure for the world’s leading institutions to build on.”
Circle also notes that regulatory alignment has been a consistent part of its strategy.
Since 2015, Circle has held a BitLicense issued by the New York Department of Financial Services. In 2024, Circle became the first stablecoin issuer to achieve full compliance with the European MiCA framework. Notably, although Tether remains the largest issuer in the stablecoin segment, it changed its jurisdiction and experienced issues following MiCA updates. In contrast, Circle and its USDC became the first MiCA-compliant stablecoin under the new European regime. In April 2025, the company also received in-principle approval from the Financial Services Regulatory Authority operating within the Abu Dhabi Global Market.
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Conclusion
If Circle secures the license and achieves compliance at this level as well, it could potentially dramatically elevate the company’s strategic role in the ecosystem. Eliminating reliance on banking counterparties and self-custody of reserves – while requiring stronger transparency across jurisdictions – may also deliver substantial practical efficiency and long-term value.
