Key Takeaways
- • The Office of the Comptroller of the Currency granted preliminary conditional approval on August 14, 2026 to World Liberty Trust Company, National Association, a proposed national trust bank that would issue and redeem the USD1 dollar-backed stablecoin issued by World Liberty Financial LLC.
- • The approval is preliminary only: the bank cannot open until all preopening requirements are met, and the OCC retains the right to modify, suspend or rescind the approval.
- • The approval carries seven enforceable conditions, including a minimum of $20 million in tier 1 capital and 180 days of operating expenses held in reserve, and the bank must confine itself to trust company operations.
- • Zachary Witkoff is named organizer, director and president, with Robert Witkoff and Scott Alper as organizers and directors, a slate the OCC posed no objection to.
- • Senator Elizabeth Warren announced the Ending Presidential Corruption in Banking Act, which would bar regulators from chartering institutions owned by the president and require review of approvals granted after January 20, 2025.
Summary
The Office of the Comptroller of the Currency granted preliminary conditional approval on August 14 to World Liberty Trust Company, National Association, according to the decision letter filed as Corporate Decision #1385. The letter, signed by Senior Deputy Comptroller for Chartering Stephen A. Lybarger, was addressed to Brandi Reynolds of SC Financial Technologies, LLC in Miami. The proposed bank would have its main office in Bay Harbor Islands, Florida, and would be a wholly owned subsidiary of WLTC Holdings LLC. The OCC noted in a footnote that USD1 is a core product of World Liberty Financial LLC and that the two entities share indirect common owners.
The proposed bank would take over USD1 issuance and custody from BitGo Bank & Trust, National Association, the current exclusive issuer and custodian. Its three proposed lines of business are stablecoin issuance, redemption and reserve maintenance in a nonfiduciary capacity; digital asset custody as a fiduciary; and conversion services allowing custody customers to exchange approved stablecoins for USD1. The OCC also approved the planned purchase of USD1 reserve assets from BitGo as exempt from certain Regulation W limits. Three investors filed commitments that their indirect investments are passive.
The approval is not final. The OCC states that final authorization to commence business will not be granted until all preopening requirements are met, and the preliminary approval expires if the bank does not raise capital within 12 months or open within 18 months. The conditions include a minimum of $20 million in tier 1 capital and a separately held reserve of 180 days of operating expenses, and for three years the bank must give 60 days' notice before deviating from its business plan. Organizers and officers the OCC did not object to include Zachary Witkoff, Robert Witkoff, Scott Alper, Jeffrey Weiner, Erin Baskett, Mack McCain and Brandi Reynolds.
The OCC received seven comments from four commenters on the January application, several raising conflict-of-interest concerns tied to President Donald Trump, his family, and United Arab Emirates investors in World Liberty Financial, Inc. The agency responded that the Comptroller and staff acted consistently with their statutory and ethical duties, and that approvals are made under authority delegated to career staff. Jonathan V. Gould, the Comptroller since July 15, 2025, is a Trump nominee. The OCC set aside Emoluments Clause and CFIUS concerns as outside its review, and found the Community Reinvestment Act inapplicable because the bank will not be an insured depository institution.
Senator Elizabeth Warren of Massachusetts said on August 15 that she and colleagues would introduce the Ending Presidential Corruption in Banking Act. Warren said the president is the first in history to approve, operate and supervise his own bank. The bill would bar the Federal Reserve, OCC and FDIC from approving charters, deposit insurance or master accounts for institutions owned or controlled by the president, vice president, their family members, members of Congress, or presidentially appointed officials, and would require review of approvals granted after January 20, 2025. World Liberty Financial said in a statement reported by Newsweek that it is running toward regulation and continuous oversight, and that the national charter would bring robust supervision from the OCC.
The proposed bank would take over USD1 issuance and custody from BitGo Bank & Trust, National Association, the current exclusive issuer and custodian. Its three proposed lines of business are stablecoin issuance, redemption and reserve maintenance in a nonfiduciary capacity; digital asset custody as a fiduciary; and conversion services allowing custody customers to exchange approved stablecoins for USD1. The OCC also approved the planned purchase of USD1 reserve assets from BitGo as exempt from certain Regulation W limits. Three investors filed commitments that their indirect investments are passive.
The approval is not final. The OCC states that final authorization to commence business will not be granted until all preopening requirements are met, and the preliminary approval expires if the bank does not raise capital within 12 months or open within 18 months. The conditions include a minimum of $20 million in tier 1 capital and a separately held reserve of 180 days of operating expenses, and for three years the bank must give 60 days' notice before deviating from its business plan. Organizers and officers the OCC did not object to include Zachary Witkoff, Robert Witkoff, Scott Alper, Jeffrey Weiner, Erin Baskett, Mack McCain and Brandi Reynolds.
The OCC received seven comments from four commenters on the January application, several raising conflict-of-interest concerns tied to President Donald Trump, his family, and United Arab Emirates investors in World Liberty Financial, Inc. The agency responded that the Comptroller and staff acted consistently with their statutory and ethical duties, and that approvals are made under authority delegated to career staff. Jonathan V. Gould, the Comptroller since July 15, 2025, is a Trump nominee. The OCC set aside Emoluments Clause and CFIUS concerns as outside its review, and found the Community Reinvestment Act inapplicable because the bank will not be an insured depository institution.
Senator Elizabeth Warren of Massachusetts said on August 15 that she and colleagues would introduce the Ending Presidential Corruption in Banking Act. Warren said the president is the first in history to approve, operate and supervise his own bank. The bill would bar the Federal Reserve, OCC and FDIC from approving charters, deposit insurance or master accounts for institutions owned or controlled by the president, vice president, their family members, members of Congress, or presidentially appointed officials, and would require review of approvals granted after January 20, 2025. World Liberty Financial said in a statement reported by Newsweek that it is running toward regulation and continuous oversight, and that the national charter would bring robust supervision from the OCC.
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