Circle has received conditional approval from the OCC to establish a national trust bank!
According to the official announcement released by Circle (CRCL.US) on December 12, 2025, Eastern Time, the Office of the Comptroller of the Currency (OCC) has formally granted conditional approval for Circle to establish the "First National Digital Currency Bank, NA." This is a significant advancement following the application submitted in June 2025, marking a key step for Circle towards becoming a compliant financial infrastructure.
⚠️ What does “conditional approval” mean?
1. Not final
The OCC requires Circle to complete the following key tasks within 180 days to obtain the final license:
Capital adequacy: It must prove that the bank's initial capital is not less than $120 million (OCC's minimum requirement);
System compliance testing: Pass audits on anti-money laundering (AML), cybersecurity, operational risks, etc.;
Executive appointment approval: Board members and the CEO must pass OCC background checks.
2. Regulatory reserve rights
If Circle fails to meet the standards within the deadline, the OCC has the right to withdraw the approval. Historical data shows that the final approval rate for OCC conditional approval projects is about 85%.
Circle's strategic intentions and impacts
1. Completely address the custody risk of USDC reserve assets
Current pain point: Currently, the $68 billion USDC reserves are held by BNY Mellon, which poses a “third-party dependency risk” (as seen in the 2023 Silicon Valley Bank incident);
Future plan: The new bank will directly hold over 80% of the USDC reserve assets (mainly short-term U.S. Treasury bonds), achieving a “issuance-custody” closed loop, significantly reducing systemic risk.
2. Expand full-stack digital asset services
Institutional-level custody, providing custody services for hedge funds and asset management companies for mainstream cryptocurrencies like BTC/ETH
Tokenized securities clearing, supporting the tokenized issuance and clearing of stocks and bonds (e.g., BlackRock's BUIDL fund)
Cross-border payment network, real-time cross-border settlement based on USDC (replacing SWIFT)
3. Cost optimization and profit enhancement
Expected to save over $40 million in third-party custody fees annually (accounting for 60% of current custody costs)
New business lines could contribute an additional $200-300 million/year in revenue (Morgan Stanley forecast).
