The Office of the Comptroller of the Currency granted conditional national trust bank charters to three digital-asset firms — Bastion Platforms, Catena Trust Bank, and Agora National Trust Bank — on September 18, 2026. The approvals bring the total number of crypto-related conditional charters to...
"Congress did not create the national trust charter as a side door into the banking system for crypto firms seeking the credibility of a federal bank charter." — Rebeca Romero Rainey, President and CEO, Independent Community Bankers of America
The Office of the Comptroller of the Currency granted conditional national trust bank charters to three digital-asset firms — Bastion Platforms, Catena Trust Bank, and Agora National Trust Bank — on September 18, 2026. The approvals bring the total number of crypto-related conditional charters to at least 14 since December 2025, when the OCC ended a four-year freeze on new digital-asset banking licenses. Only two firms, Anchorage Digital and Circle, have completed the process to full operational status.
On October 2, the Independent Community Bankers of America (ICBA) filed suit in the U.S. District Court for the District of Columbia under the Administrative Procedure Act, seeking to overturn the OCC's March 2, 2026 final rule tied to Interpretive Letter No. 1176. The complaint argues the OCC exceeded its statutory authority by allowing crypto firms access to national trust charters without imposing Community Reinvestment Act obligations, FDIC insurance requirements, or consolidated supervision equivalent to traditional banks. The lawsuit singles out Protego Holdings Corp.'s conditional charter for vacatur.
The three new charters are notable not for their number but for their composition: Bastion issues white-label stablecoins for banks, Agora seeks to migrate its $230 million AUSD stablecoin from Bermuda to a federally regulated entity, and Catena — co-founded by Circle co-founder Sean Neville — is building what it describes as the first AI-native financial institution designed to serve autonomous software agents.
All three approvals are conditional. Agora and Catena received preliminary conditional approval for de novo national trust banks and must obtain final OCC approval plus permission to commence business before opening. Bastion received conditional approval to convert its existing New York state-limited trust company (acquired in February 2025 via the purchase of Dibbs Trust Company) to a national trust bank under OCC Charter #27198.
None of the three entities may accept deposits. None qualify for FDIC insurance. The charters restrict operations to trust-company business, and all three must secure Federal Reserve bank stock before full approval. Bastion must complete its conversion within six months.
The permitted activities span:
The OCC set differentiated capital floors:
| Firm | Minimum Tier 1 Capital | Liquid Asset Minimum | Liquidity Buffer | |------|----------------------|---------------------|------------------| | Agora | $10 million | $5 million (50%) | 180 days operating expenses | | Catena | $10 million | $5 million (50%) | 180 days operating expenses | | Bastion | $6 million | $3 million (50%) | 180 days operating expenses |
All three must maintain 180 days of operating expenses in eligible liquid assets during their first three years of operation. The lower capital floor for Bastion reflects its conversion from an existing state-chartered trust company rather than a de novo application.
Catena Trust Bank, led by Circle co-founder Sean Neville, is the most unusual of the three approvals. The firm raised $18 million in a seed round led by a16z crypto, followed by a $30 million Series A led by Acrew Capital and a16z crypto, for total disclosed funding of $48 million.
Catena describes itself as building "a financial institution for AI agents and the businesses that put them to work." The platform provides fiduciary infrastructure allowing autonomous agents to conduct financial transactions within defined boundaries. Its governance layer lets humans set spending limits, define approved recipients, cap account holdings, and establish audit trails before handing financial execution to software agents.
The firm has published an open-source agent commerce kit outlining protocols for what it calls "agentic commerce." According to Catena's website, the platform utilizes "deterministic policy enforcement, immutable audit trails, and verifiable agent identity."
Banking groups opposed the approval, according to OCC filings, citing misalignment with precedent on trust bank fiduciary activities. The OCC dismissed these concerns. Whether a trust bank primarily serving non-human autonomous agents constitutes "fiduciary" activity within the meaning of the National Bank Act remains an open legal question — one the ICBA lawsuit may ultimately test.
Agora, founded in October 2023 by Nick van Eck (son of VanEck CEO Jan van Eck), Drake Evans, and Joe McGrady, issues the AUSD stablecoin. AUSD currently has approximately $230 million in market capitalization. Each token is backed 1:1 by cash, short-duration U.S. Treasury bills, and overnight reverse repurchase agreements held in a segregated reserve fund. Reserves are managed by VanEck and custodied at State Street.
Agora raised a $50 million Series A led by Paradigm. AUSD is live on multiple chains including Ethereum, Solana, and Monad.
The national trust charter, if finalized, would allow Agora to transfer AUSD issuance from its current Bermuda-based entity to a New York-based, federally regulated bank. Nick van Eck stated the charter provides "the regulatory layer that makes all of that possible at scale." The onshoring is consistent with the GENIUS Act framework, which distinguishes between federally chartered and state-licensed stablecoin issuers and imposes different reserve and reporting obligations on each.
Applied for in April 2026, Agora's charter moved from application to preliminary conditional approval in approximately five months.
Bastion Platforms, founded in 2023 by former Andreessen Horowitz crypto executives, operates as stablecoin infrastructure for financial institutions. Its primary service line is white-label stablecoin issuance — building, maintaining, and operating stablecoins on behalf of banks and fintechs that want to offer dollar-denominated tokens under their own brand.
The firm has disclosed $14.6 million in funding from Coinbase Ventures, Sony Innovation Fund, and Samsung Next. Its existing client roster includes Sony Bank, which has a partnership for stablecoin services. Bastion also hired Michael Patterson, formerly Genesis's compliance officer.
CEO Nassim Eddequiouaq framed the charter as enabling Bastion to be "that regulated partner for all of the largest financial institutions." The conversion from New York state trust (OCC Charter #27198) to a national trust company is designed to provide federal preemption of state-by-state licensing requirements — the same preemption advantage that the CSBS and ICBA are now challenging in court.
The ICBA filed its complaint on October 2, 2026, in the U.S. District Court for the District of Columbia. The suit targets the OCC's March 2, 2026 final rule and Interpretive Letter No. 1176, which the ICBA says "exceed statutory authority under the National Bank Act."
The core argument: crypto firms are obtaining national trust bank charters while avoiding the regulatory obligations applied to traditional community banks. Specifically, the ICBA cites the absence of Community Reinvestment Act obligations, consolidated supervision, equivalent capital and liquidity standards, and FDIC insurance requirements. The complaint asks the court to vacate Protego Holdings Corp.'s conditionally approved trust charter.
The ICBA is not alone. The Conference of State Bank Supervisors (CSBS) submitted a comment letter arguing that "Congress did not give the OCC open-ended, 'choose your own adventure' chartering authority." CSBS contends that the OCC's removal of the word "fiduciary" from its trust bank regulation does not change the National Bank Act's requirement that national trust companies must be engaged predominantly in fiduciary activities.
Senator Elizabeth Warren has separately pressed the OCC on the approvals, questioning whether crypto firms are using special charters to "act like banks while evading bank rules."
A Duke University FinReg Blog analysis published in May 2026 characterized the OCC's stablecoin charter push as "illegal, dangerous, and likely to end in bailouts."
The OCC has not commented on the lawsuit. Previously, the agency stated its rule "clarifies" existing authority and "would neither expand nor contract" its chartering powers. Comptroller Jonathan Gould, who has led the charter policy, noted that more than half of recent bank charter applications involve digital assets.
The velocity of crypto charter approvals has accelerated sharply. Between 2021 and 2024, the OCC granted only three conditional approvals — Anchorage (January 2021), Protego (February 2021), and Paxos (April 2021) — before entering a de facto freeze under Acting Comptroller Michael Hsu.
That freeze ended in December 2025. In eighty-three days, the OCC took eleven crypto and fintech firms through federal bank chartering. The December 2025 batch included Circle, Ripple, BitGo, Fidelity Digital Assets, and Paxos Trust Company. February 2026 added Protego (re-filed), Stripe's subsidiary Bridge, and Crypto.com. September 2026 added Bastion, Catena, and Agora.
The OCC has received 40 applications for bank charters in roughly the last 18 months. Twenty-three — more than half — involve digital asset activity. That compares to 48 total applications during the entire 2011–2024 period.
Of all conditional approvals granted, only two firms have reached full operational status. Anchorage Digital has been operating since 2021. Circle's First National Digital Currency Bank received final approval on July 10, 2026, becoming the first crypto-native firm to complete the full journey since Anchorage.
The gap between conditional approval and operational readiness is the critical bottleneck. As one analysis noted: "A federal trust charter remains valuable in that market. Its role increasingly resembles an entry requirement, while the durable moat has to be built through distribution, liquidity, and execution."
The September 18 approvals extend a pattern that began in December 2025: the OCC is processing crypto charter applications at a pace that outstrips both its own historical norms and the industry's ability to reach operational status. Conditional approval is not the finish line. Final approval, capital adequacy, reserve relationships, distribution, and sustained execution remain the harder tests.
The ICBA lawsuit introduces a legal variable. If the D.C. district court agrees that the OCC exceeded its statutory authority under the National Bank Act, the entire post-2025 charter framework could face vacatur. That outcome would affect not just the three September approvals but potentially all conditional charters issued under the same rule.
For Catena, the question is more foundational: whether the National Bank Act's trust framework, written for human beneficiaries, can accommodate autonomous software agents as financial clients. The OCC has said yes. The courts have not yet weighed in.
The stablecoin market, currently at approximately $304 billion, is absorbing new entrants — bank-backed, fintech-backed, and now AI-agent-backed — faster than the legal infrastructure supporting them has been resolved. The GENIUS Act's final implementing rule, expected from the OCC by November, may clarify some boundaries. The ICBA litigation will test others.