The Office of the Comptroller of the Currency granted preliminary conditional approval on August 14 to World Liberty Trust Company, National Association, a proposed national trust bank that plans to issue and redeem USD1, a dollar-backed stablecoin sold by World Liberty Financial LLC.
The decision letter, filed as Corporate Decision #1385, was signed by Stephen A. Lybarger, the OCC’s Senior Deputy Comptroller for Chartering, Organization and Structure, and addressed to Brandi Reynolds of SC Financial Technologies, LLC in Miami. It records the application as OCC Control No. 2026-Charter-344521, with proposed charter number 25407, and the bank’s main office in Bay Harbor Islands, Florida.
Approval at this stage does not let the bank open. “The OCC has granted preliminary conditional approval only,” the letter states. “Final approval and authorization pursuant to 12 USC 27(a) for the Bank to commence business will not be granted until all preopening requirements are met.” Until then, the agency says it retains the right to modify, suspend or rescind the approval.
What the bank would be allowed to do
The letter describes three lines of proposed business: dollar-backed stablecoin issuance, redemption and reserve maintenance in a nonfiduciary capacity; digital asset custody services as a fiduciary; and conversion services allowing custody customers to exchange approved stablecoins for USD1. The bank would take over USD1 issuance and custody from BitGo Bank & Trust, National Association, which the letter identifies as the current exclusive issuer and custodian for the token.
The bank would be a wholly owned subsidiary of WLTC Holdings LLC, a Delaware limited liability company. In a footnote, the OCC states that USD1 “is one of the core products of World Liberty Financial LLC, a Florida limited liability company,” and that “World Liberty Financial LLC and the Bank share indirect common owners.”
The agency posed no objection to a slate of organizers and officers that includes Zachary Witkoff as organizer, director and president, Robert Witkoff and Scott Alper as organizers and directors, Jeffrey Weiner and Erin Baskett as independent directors, Mack McCain as chief trust officer, and Reynolds as chief compliance officer.
Conflict-of-interest comments, and the agency’s answer
The OCC says it received seven comments from four commenters on the January application. “Four commenters expressed concerns about potential conflicts of interest involving the Bank, President Donald J. Trump and his family, Alexander and Zachary Witkoff, and United Arab Emirates investors in World Liberty Financial, Inc.,” the letter states. Three of them argued the bank could receive preferential treatment because the Comptroller is a presidential appointee, and one suggested the Comptroller could decline to enforce the law against the bank or over-enforce it against rivals.
The agency’s response is two sentences: “The Comptroller and staff acted consistently with their statutory duties and ethical obligations with respect to the Application. Approvals of applications such as this are made under authority delegated by the Comptroller to career staff.” Jonathan V. Gould, whom Trump nominated in February 2025 and the Senate confirmed on a vote of 50 to 45, took office as the 32nd Comptroller of the Currency on July 15, 2025.
One commenter argued that certain purchases of WLFI tokens could violate the Constitution’s Emoluments Clause. The OCC placed that outside its review, writing that such comments “are outside the scope of the OCC’s review because neither World Liberty Financial, Inc., nor any foreign investors in that entity, are a party to this application,” and adding that “the Bank will not issue, custody, or deal in WLFI tokens.” Calls for a Committee on Foreign Investment in the United States review of Emirati investment in World Liberty Financial were set aside on the same ground.
Four commenters raised the Community Reinvestment Act, the 1977 law under which regulators assess how insured banks meet the credit needs of their local communities. The OCC wrote that the law “is not applicable to the Bank as a matter of law” because it applies to insured depository institutions, and the bank will not be one. Under the GENIUS Act, the letter notes, payment stablecoins are not deposits and are not covered by federal deposit insurance.
The conditions attached
The approval carries seven conditions the OCC describes as enforceable under 12 USC 1818. The bank must confine itself to trust company operations and must not meet the Bank Holding Company Act definition of a “bank.” It must conform, cease or divest its stablecoin activities if they fall out of compliance with the GENIUS Act. It must hold at least $20 million in tier 1 capital, with the greater of half that capital or $10 million in eligible liquid assets, plus 180 days of operating expenses held separately in the same form. For its first three years it must give the OCC 60 days’ notice before deviating from its business plan.
In the same letter, the OCC approved the planned purchase of USD1 reserve assets from BitGo as exempt from the quantitative limits, collateral requirements and low-quality asset prohibition of Regulation W. Three investors, StringZ Holdings RSC (DE) LLC, DT Marks SC LLC and AMGUS, LLC, filed written commitments that their indirect investments in the bank are passive.
A bill in response
Senator Elizabeth Warren of Massachusetts said on August 15 that she and a group of colleagues would introduce the Ending Presidential Corruption in Banking Act. “President Trump is now the first President in history to approve, operate, and supervise his own bank,” Warren said. “This is the most brazen act of self-dealing our financial system has ever seen.”
The bill would bar the Federal Reserve, the OCC and the Federal Deposit Insurance Corporation from approving charters, deposit insurance or master accounts for institutions owned or controlled by the president, the vice president, their spouses or children, members of Congress, presidentially appointed officials or special government employees. It would also require the three agencies, within 60 days of enactment, to review every banking application approved after January 20, 2025, and terminate approvals granted while a covered person held an ownership stake. Warren listed Chris Van Hollen, Angela Alsobrooks, Chris Murphy, Bernie Sanders, Richard Blumenthal, Jack Reed, Andy Kim, Tammy Duckworth and Ruben Gallego as cosponsors.
World Liberty Financial said in a statement reported by Newsweek that it is “running towards regulation and continuous oversight, not away from it,” and that the national charter would bring “robust and permanent regulatory supervision from the OCC.”
The preliminary approval expires if the bank does not raise its capital within 12 months or does not open for business within 18 months. Before final approval, the organizers must request a preopening examination and submit a letter to the OCC’s chartering staff, at least 60 days before the planned opening date, certifying that every condition has been met.
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