The Office of the Comptroller of the Currency (OCC) granted World Liberty Financial (WLFI) preliminary conditional approval for a national trust bank that will take over issuance and custody of the USD1 stablecoin from BitGo Bank & Trust.
The approval is preliminary and conditional. The bank must raise $20 million in tier 1 capital and meet preopening requirements before it can commence business. Issuance and custody of the USD1 stablecoin will move away from BitGo Bank & Trust under a national trust bank charter that the OCC conditionally approved on August 14.
Approval Is Preliminary, With an 18-Month Clock
The OCC granted preliminary conditional approval to World Liberty Trust Company, National Association, to be based in Bay Harbor Islands, Florida, under Corporate Decision #1385. Final approval to commence business will not be granted until all preopening requirements are met, and the OCC states it may modify, suspend, or rescind the approval if any interim development warrants it.
The approval expires if capital is not raised within 12 months or the bank does not open within 18 months. The OCC states it is opposed to granting extensions except in the most extenuating circumstances. The decision was signed by Stephen A. Lybarger, senior deputy comptroller for chartering, organization, and structure.
A national trust bank is a federally chartered institution limited to the operations of a trust company. It does not take insured deposits and is not covered by federal deposit insurance. WLTC Holdings LLC filed the application in January 2026, which The Crypto Times reported at the time.
Bank Will Assume USD1 Issuance From BitGo
The bank plans to issue USD1 to institutional clients nationwide, assuming the role from BitGo Bank & Trust, National Association, which the decision identifies as the current exclusive issuer and custodian for the stablecoin. BitGo received its own conditional charter in December 2025 alongside Ripple, Fidelity Digital Assets, Paxos, and Circle, which The Crypto Times reported.
USD1 is described in the decision as one of the core products of World Liberty Financial LLC, a Florida company that shares indirect common owners with the bank. Its proposed activities are dollar-backed stablecoin issuance, redemption, and reserve maintenance in a non-fiduciary capacity; digital asset custody as a fiduciary; and conversion services allowing custody customers to exchange approved stablecoins for USD1. Fiduciary custody means the bank holds assets under a legal duty to act in the customer’s interest, subject to fiduciary standards.
The bank would be a wholly owned subsidiary of WLTC Holdings LLC, a Delaware company. The application was filed by SC Financial Technologies, LLC of Miami.
Regulation W Exemption Granted for the Reserve Transfer
After the bank is established, it intends to acquire USD1 reserve assets and associated liabilities from BitGo. The OCC states that transfer could count as a covered transaction under Section 23A of the Federal Reserve Act and Regulation W, which restricts transactions between a bank and its affiliates.
The OCC approved the purchase as exempt from Regulation W’s quantitative limits, collateral requirements, and low-quality asset prohibition, using an exemption available where the chartering agency reviews a new bank’s asset purchase in writing. The transaction remains subject to Regulation W’s safety and soundness requirement.
Zachary Witkoff Named President
The OCC posed no objection to Zachary Witkoff serving as organizer, director, and president. Scott Alper and Robert Witkoff are listed as organizers and directors, with Jeffrey Weiner and Erin Baskett as organizers and independent directors.
Mack McCain is listed as chief trust officer, Brandi Reynolds as chief compliance officer, Himang Patel as Bank Secrecy Act officer, Chris McNab as chief information security officer, and Corey Caplan as chief technology officer.
Three Investors Filed Passivity Commitments
StringZ Holdings RSC (DE) LLC, DT Marks SC LLC, and AMGUS, LLC, each committed that their indirect investments in the bank are passive, in commitments attached to the decision as exhibits.
The DT Marks SC LLC commitment is signed by Eric F. Trump as president. The StringZ Holding RSC (DE) LLC commitment is signed by Hamad Khlfan Ali Matar Alshamsi as manager, and the AMGUS commitment by Zachary Folkman as managing member.
Under the commitments, each investor agrees not to seek board representation, propose directors, solicit proxies, seek material non-public information, or attempt to influence management decisions. Any holding of 10% or more must be exclusively for investment purposes, and voting shares above 9.9% must be proxied to management and voted in proportion with other shareholders.
The decision gives two different dates for the commitments, referring in one place to a letter dated July 13, 2026, and in another to commitments dated June 13, 2026.
Four Commenters Raised Conflict-of-Interest Objections
The OCC received seven comments from four commenters. Four raised concerns about potential conflicts of interest involving President Donald J. Trump and his family, Alexander and Zachary Witkoff, and United Arab Emirati investors in World Liberty Financial, Inc.
Three commenters said the bank could receive preferential treatment because the Comptroller is a presidential appointee. One said the Comptroller could abstain from enforcing laws against the bank or over-enforce against its rivals. One said certain purchases of WLFI tokens could potentially violate the Emoluments Clause and implicate national security concerns. Several said the OCC should not approve the application unless the Committee on Foreign Investment in the United States reviewed World Liberty Financial, Inc.’s ownership structure.
OCC Says Career Staff Reviewed the Application
The OCC states that the Comptroller and staff acted consistently with their statutory duties and ethical obligations, that approvals of applications such as this are made under authority delegated by the Comptroller to career staff, and that career staff reviewed the application and will be responsible for supervising the bank.
On the Emoluments and CFIUS objections, the OCC states that the bank will not issue, custody, or deal in WLFI tokens, and that those comments fall outside the scope of its review because neither World Liberty Financial, Inc. nor any foreign investors in it are a party to the application. It states that investors in World Liberty Financial, Inc. would not have an investment in or control over the bank.
The OCC also states that stablecoins are not deposits under the Federal Deposit Insurance Act, citing the GENIUS Act, and that the Community Reinvestment Act does not apply because the bank will not be an insured depository institution.
Chartering Authority Contested Since December
Two commenters questioned the OCC’s authority to charter the bank, arguing the proposed activities do not align with OCC precedent on fiduciary activities conducted by national trust banks. The OCC states it is authorized to charter national banks under the National Bank Act and that the proposed activities are permissible.
Senator Elizabeth Warren has argued that the wave of crypto trust charters exceeds the OCC’s statutory authority, in reporting The Crypto Times covered in May, when World Liberty Financial’s application was pending. At least 11 crypto and fintech companies had filed for or received charters in roughly 83 days from December 2025.
The OCC states that as of March 31, 2026, OCC-supervised uninsured national trust banks reported $7.2 trillion in assets under administration, of which $1.7 trillion consisted of custody and safekeeping accounts and $5.5 trillion of fiduciary accounts.
Capital Floor Set at $20 Million
The approval carries seven conditions. The bank must maintain at least $20 million in tier 1 capital, with the greater of 50% of that or $10 million held in eligible liquid assets, and must separately hold 180 days of operating expenses in eligible liquid assets. Both conditions run for three years.
The bank must give 60 days’ written notice and obtain a no-objection determination before any significant deviation from its business plan, must obtain OCC no-objection before appointing senior executive officers or directors, and must designate an internal audit manager independent of the activities audited.
A further condition requires the bank to conform, cease, or divest its stablecoin activities to comply with the GENIUS Act and any implementing regulations, with compliance determined at the OCC’s sole discretion. The bank has committed not to become a “bank” under the Bank Holding Company Act and does not plan to seek a Federal Reserve master account, according to the decision.
The OCC said on August 12 that it has received 40 de novo applications over the past 18 months, including applications for national trust banks, and has reached decisions on some within 120 days of receiving a complete application.
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