The Office of the Comptroller of the Currency is the federal supervisor for national banks, federal savings associations, and federally licensed branches and agencies of foreign banks, and on tokenisation it is the load-bearing US regulator for bank-money-on-chain. The OCC's interpretive-letter sequence (1170 crypto custody, 1172 stablecoin reserves, 1174 stablecoin payments, 1184 the trust-bank crypto-activities update) is the legal scaffolding under which JPMorgan operates Kinexys as a deposit-liability rail rather than a stablecoin issuer, and under which Anchorage Digital, Circle, Ripple, BitGo, Fidelity Digital Assets, Paxos, and others either hold or have applied for national trust bank charters. For a tokenisation operator, the OCC is the federal counterparty for bank-side tokenised deposits, the trust-bank chartering programme that gives crypto-native firms a single federal alternative to 51 state licences, and the supervisor for the federally qualified non-bank stablecoin issuer route under the GENIUS Act.
Role in tokenisation
The OCC's tokenisation surface has three load-bearing components. First, the interpretive-letter lineage. IL 1170 (2020) clarified that national banks can hold cryptoassets in custody for clients. IL 1172 (2020) clarified that national banks can hold reserves backing dollar-denominated stablecoins. IL 1174 (2021) clarified that national banks can engage in stablecoin payment activities, including verifying, storing, and recording payments on a blockchain. The letters were rescinded under the prior administration, restored under the current one, and now sit as live guidance with 2025 supplementary letters covering tokenised-deposit ledger participation. The structural read is that the OCC's posture allows JPMorgan Chase Bank, N.A. (a national bank) to operate the Kinexys ledger and the BDA (blockchain deposit account) construct as deposit liabilities under its existing national-bank charter, deliberately outside the GENIUS Act payment-stablecoin perimeter and inside the existing banking-licence regime.
Second, the national trust bank charter for crypto-and-fintech activities. The OCC's April 2026 final rule clarified that national trust banks can conduct non-fiduciary activities including crypto custody under a single federal framework replacing 51 state licences. Anchorage Digital is the only firm with a full charter as of April 2026; conditional approvals through 2025-2026 cover Circle, Ripple, BitGo, Fidelity Digital Assets, Paxos, Stripe's Bridge, Crypto.com, and Protego, with Zerohash (filed March 2026) and Morgan Stanley Digital Trust (filed February 2026) among the firms with applications pending. The Bank Policy Institute is reportedly considering a lawsuit challenging the chartering programme on the grounds that the OCC has reinterpreted federal licensing rules to allow crypto firms entry under lighter oversight than full-service banks.
Third, the GENIUS Act federal-non-bank issuer supervision role. Under GENIUS, federally qualified non-bank stablecoin issuers register with and are supervised by the OCC. The Comptroller's office is one of the three federal banking agencies (alongside the Federal Reserve and FDIC) running the rule-making process on the implementing regulations, with proposed rules published in late 2025 and final rules expected through 2026 (Federal Register OCC GENIUS rule). The structural effect is that the OCC supervises both bank-issued tokenised deposits (under the existing national-bank perimeter) and federally qualified non-bank payment stablecoins (under the GENIUS perimeter), giving the OCC the broadest tokenisation supervisory footprint of any single US federal agency.
Operating model
The OCC's regulatory toolkit on tokenisation runs through three distinct routes. The national-bank charter route covers JPMorgan, Bank of America, Citi, BNY, State Street, and other federally chartered banks; their tokenised-deposit and crypto-custody activities are supervised under the existing national-bank framework with the interpretive-letter lineage as the operational guidance. The national trust bank route covers Anchorage and the conditional-approval cohort; supervision runs under the trust-bank charter framework with crypto custody specifically authorised as a non-fiduciary activity. The federally qualified non-bank stablecoin issuer route under GENIUS covers stablecoin issuers operating outside the bank charter; supervision runs under the GENIUS Act statutory framework with reserve, redemption, and disclosure requirements.
The interpretive-letter mechanism is the OCC's distinctive supervisory tool. Rather than rule-making, the OCC publishes letters in response to specific bank inquiries, with the letters then operating as broader guidance. The 2020-2021 lineage and the 2025 supplementary letters cover most of the OCC's published tokenisation guidance. The mechanism is faster than rule-making but more vulnerable to administration changes: the rescission and restoration sequence across the prior and current administrations is the worked example.
The trust-bank chartering programme moves through a conventional licensing process. The firm submits a chartering application, undergoes regulatory review covering capital adequacy, governance, risk management, and the proposed business plan, and receives either a conditional approval (with operating conditions to be satisfied before the charter takes full effect) or a final charter. The transition from conditional to full approval requires satisfying each condition and an OCC determination that the firm is operating in a safe and sound manner. Anchorage's multi-year transition from conditional to final approval is the only worked example of the full path; the other firms with conditional approvals are following a similar but uncalibrated timeline.
Why it matters
Three structural reasons. First, the OCC's interpretive-letter lineage is what allows GSIB-scale tokenised deposits to operate as deposit liabilities rather than stablecoins. Kinexys's USD 3 trillion cumulative notional and USD 5 billion-plus daily volume sit under that lineage, not under GENIUS. The legal architecture is part of why JPMorgan has been willing to commit GSIB balance-sheet to the rail. Second, the trust-bank chartering programme is the structural unlock for crypto-native firms to compete on a federal regulatory footing rather than running 51 state licences. The economic consequence is material: maintaining 51 separate state licences with the associated capital, examination, and reporting overhead is a multi-year multi-million-dollar undertaking that the federal charter collapses into one. Third, the OCC sits at the intersection of bank-money tokenisation and federally qualified stablecoins, which makes it the single most consequential US federal regulator for the cash-leg of tokenised settlement.
The competitive frame is partly the Federal Reserve (which has been permissive on tokenised deposits in principle and slow on plumbing in practice, with no FedNow-adjacent on-chain bridge yet authorised), partly the SEC (tokenised securities and tokenised funds), partly the CFTC (digital-asset commodities and tokenised collateral). The OCC's posture has been the most consistently permissive of the four federal regulators on permissioned-ledger experimentation, in part because its statutory mandate (national-bank chartering and supervision) gives it more latitude on structural questions than the securities and commodities regulators have under their respective Acts.
Recent moves
- April 2026. OCC final rule on non-fiduciary trust bank activities takes effect, clarifying that national trust banks can conduct crypto custody under the federal trust-bank framework (US OCC trust bank charter).
- 2025-2026. Conditional approvals for Circle, Ripple, BitGo, Fidelity Digital Assets, Paxos (December 2025); Stripe's Bridge, Crypto.com, Protego (early 2026).
- December 2025. Federal Register notice of proposed rule-making for GENIUS Act payment-stablecoin issuance by subsidiaries of FDIC-supervised insured depository institutions.
-
- OCC supplementary letters cover tokenised-deposit ledger participation and update the perimeter.
- 2020-2021. Interpretive Letters 1170, 1172, 1174 published, establishing the federal-bank crypto-custody, stablecoin-reserve, and stablecoin-payment perimeters.
Open questions
- Whether the Bank Policy Institute legal challenge to the OCC chartering programme survives judicial review. If it succeeds, the entire programme is at risk, including every pending application.
- Whether the Federal Reserve extends master-account access to OCC trust-bank charter holders. This is the long-tail bet that determines whether the charter is a structural moat or a regulatory checkbox.
- How the OCC treats permitted GENIUS issuers that hold reserves in tokenised money-market funds, given the GENIUS reserve composition list permits MMFs invested in qualifying assets.
- The interaction with state regulators in jurisdictions with substantial crypto-licensing programmes (NYDFS BitLicense and limited-purpose trust charter, Wyoming Special Purpose Depository Institution).
- Whether the OCC publishes consolidated guidance on tokenised-deposit cross-bank interoperability, or whether bilateral and consortium arrangements remain the operational pattern.