OCC Grants World Liberty Trust Company Conditional Approval

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The approval lets the Trump-linked firm behind USD1 prepare to operate under direct federal supervision. Still, the bank cannot open or take on customers yet. First it must clear a long list of preopening conditions.

What the OCC Actually Approved

The OCC granted approval to organize only. According to the letter, final authorization to commence business will not come until the bank meets every preopening requirement. Until then, the regulator can modify, suspend, or rescind the decision.

The proposed bank would sit in Bay Harbor Islands, Florida. It would be a wholly owned subsidiary of WLTC Holdings LLC. Notably, it would be an uninsured national trust bank, not a full commercial bank.

As a result, it would not take insured deposits, make loans, or seek a Federal Reserve master account. Instead, it would focus strictly on trust and fiduciary activities tied to USD1.

What the World Liberty Trust Company Would Do

The plan gives the World Liberty Trust Company three main jobs. First, it would issue and redeem USD1 and maintain the reserve in a nonfiduciary capacity.

Second, it would provide digital asset custody to institutional clients as a fiduciary. Third, it would offer conversion services for those custody customers.

Notably, the firm intends to take over the issuer and custodian role currently held by BitGo Bank & Trust. That transition would bring USD1 issuance, custody, and reserve management under one roof.

The Conditions Are Strict

The approval carries seven primary conditions plus extensive preopening requirements. In short, the OCC wants proof before it lets the bank open.

The bank must hold at least $20 million in tier 1 capital. Of that, the greater of 50% or $10 million must sit in Eligible Liquid Assets. On top of that, it must hold 180 days of operating expenses in liquid assets for the first three years.

In addition, the firm must conform its stablecoin activities to the GENIUS Act, or cease and divest if it cannot. It also needs OCC non-objection before naming senior officers or directors. On top of that, it must designate a qualified independent internal audit manager.

The Clock Is Already Ticking

Timing is tight. The bank must raise its capital within 12 months of the August 14 letter. It must also open within 18 months, or the preliminary approval expires. In addition, it must apply for stock in a Federal Reserve Bank.

Moreover, the OCC said it opposes extensions except in the most extenuating circumstances. So the organizers have little room to slip.

The five-member board is led by Zachary Witkoff, co-founder of World Liberty Financial and the proposed president. According to the OCC, career official Stephen A. Lybarger signed the decision under delegated authority. That review took about 221 days.

Why a Trust Charter Matters for USD1

A national trust bank answers to one federal regulator, the OCC. That single umbrella lets a stablecoin issuer skip the patchwork of state money-transmitter licenses.

For USD1, the stakes are large. Trackers such as CoinMarketCap put its circulating supply in the multi-billion-dollar range. Reports placed it around $4 billion near the announcement. The reserve sits mainly in cash, short-term Treasuries, and government money-market funds.

Consequently, a charter could boost institutional confidence and ease GENIUS Act compliance. Lawmakers passed that federal stablecoin law in July 2025. It would also cut reliance on third-party partners.

The Conflict-of-Interest Pushback

The decision has drawn sharp criticism. The Trump family reportedly holds a large economic stake in World Liberty Financial. As a result, critics have questioned a federal charter issued under a Trump-appointed comptroller.

Sen. Elizabeth Warren and other Democrats had earlier urged a pause until any divestiture. Commenters to the OCC raised ethics, Emoluments Clause, and foreign-investor concerns. In total, the OCC said it received seven comments from four commenters.

In response, the OCC said career staff reviewed the application under delegated authority. According to the regulator, conflict questions largely fall outside the statutory charter factors. The OCC also obtained passivity commitments from several investor entities.

What Happens Next

For now, this is a milestone rather than a finish line. World Liberty Financial used that framing on August 17. The firm must still raise capital, hire, build systems, pass a preopening exam, and win final approval.

Plenty of chartered banks never open, so nothing is guaranteed. Even so, the stakes are high if the World Liberty Trust Company clears every condition. It would mark one of the clearest paths yet for a major stablecoin issuer under federal bank supervision. This article is informational only and not financial advice.