Written by Helena Markou
The Office of the Comptroller of the Currency has granted preliminary conditional approval for World Liberty Trust Company, N.A., a proposed uninsured national trust bank that plans to issue and redeem the USD1 stablecoin, maintain reserves, provide fiduciary digital-asset custody and offer limited conversion services for custody customers. The decision is consequential because it places stablecoin issuance, custody and reserve operations inside a national-trust-bank framework—but it is not permission for the institution to begin business immediately.
The OCC’s Corporate Decision 1385, dated August 14, is explicit on that point. The proposed bank still requires final approval and authorization to commence operations. Until then, the OCC can modify, suspend or rescind the preliminary conditional approval if interim developments warrant it. That distinction is important in crypto, where a charter announcement is often treated as if it were an operational launch.
If it receives final authorization, the Florida-based institution would be a wholly owned subsidiary of WLTC Holdings LLC. Its proposed activities combine three functions that are usually discussed separately. First, it would issue and redeem the dollar-backed USD1 stablecoin and maintain reserves in a nonfiduciary capacity. Second, it would provide digital-asset custody as a fiduciary. Third, it would allow custody customers to convert approved stablecoins into USD1 using assets already held in custody.
The planned handover is unusually direct. World Liberty Trust intends to assume the USD1 issuer role from BitGo Bank & Trust, the current exclusive issuer and custodian, and acquire USD1 reserve assets and associated liabilities after establishment. The OCC’s decision separately approves an exemption related to the asset transfer under Regulation W, while retaining applicable safety-and-soundness requirements. This is not merely a new brand entering stablecoins; it is an attempt to relocate an existing reserve and custody relationship into a new federally chartered trust-bank structure.
The regulatory architecture has clear limits. The OCC describes World Liberty Trust as an uninsured national trust bank. It does not plan to become an insured depository institution, and it does not plan to seek a Federal Reserve master account. The decision also states that payment stablecoins are not FDIC-insured deposits and that it is unlawful to represent them as such. For users, this is not a cosmetic distinction: a stablecoin reserve structure and bank charter do not create the same protections as a conventional insured bank deposit.
The GENIUS Act is central to the decision. The OCC says the proposed bank must conform its stablecoin activities to that law and any implementing regulations, and must cease or divest those activities if it cannot comply. The conditional nature of the approval therefore makes compliance an ongoing operational requirement, not a one-time box checked at chartering.
The potential benefit is greater institutional clarity. Fiduciary custody carries duties and standards of behavior different from ordinary wallet custody. A national-trust-bank model may give institutional users a more defined framework for custody, redemption and reserve management than an unregulated platform. The OCC also says its novel-bank supervisory unit will oversee institutions engaged in new activities.
The unresolved questions are just as important. Stablecoin issuers are judged by the quality, liquidity and transparency of reserves; a charter alone does not answer those questions. The decision notes public comments raising concerns over governance, consumer protection, anti-money-laundering controls and conflicts of interest. The OCC concluded that the application met applicable statutory and regulatory requirements, but approval does not remove the need for ongoing disclosure and supervision.
World Liberty Trust’s conditional approval is therefore best understood as a structural milestone rather than a finished product. It signals that a national trust bank can combine stablecoin issuance with fiduciary custody under current law. Whether that model builds durable confidence will depend on final authorization, reserve operations, compliance execution and the institution’s willingness to demonstrate that its protections match the seriousness of the financial role it seeks to perform.
