Crypto.com announced Monday that it has received conditional approval from the Office of the Comptroller of the Currency (OCC) to charter Foris Dax National Trust Bank, which will operate under the name Crypto.com National Trust Bank. The approval positions the exchange to offer institutional-grade custody, staking, and trade settlement services under direct federal oversight — a significant upgrade from its current state-regulated trust structure in New Hampshire.
“This conditional approval is the latest testament to both our commitment to compliance and to providing customers trusted and secure services they expect from Crypto.com,” said co-founder and CEO Kris Marszalek. “This milestone brings us a major step closer to meeting leading institutions’ needs for a one-stop-shop qualified custodian under a gold standard of federal oversight.”
Crypto.com first submitted its OCC application in October 2025. The conditional approval does not affect the company’s existing Crypto.com Custody Trust Company, which continues to operate as a qualified custodian regulated by the New Hampshire Banking Department.
What the charter actually covers
The national trust bank charter is narrower than a full bank charter. Crypto.com National Trust Bank will not accept deposits or issue loans. Instead, it will function as a limited-purpose trust bank offering digital asset custody, staking of custodied assets across multiple blockchains (including the company’s own Cronos network), and trade settlement — all under OCC oversight, per the press release.
For institutional clients — ETF sponsors, asset managers, corporate treasuries, and registered investment advisors — the federal charter eliminates the compliance friction of working with a state-regulated custodian. A single federal framework simplifies due diligence, standardizes oversight expectations, and may lower the barrier for institutions that have been hesitant to engage with crypto-native custody providers.
Crypto.com joins a growing cohort of digital asset firms that have received conditional OCC trust charters in recent months, including Circle, Ripple, BitGo, Fidelity Digital Assets, Paxos, and most recently Stripe-owned Bridge. Coinbase and Trump-affiliated World Liberty Financial have also filed applications, as reported by Decrypt.
Conditional approval is not final approval
Conditional approval is a preliminary green light, not a charter. Final approval and authorization to commence business under 12 USC 27(a) will not be granted until all preopening requirements are satisfied. Until then, the OCC retains the right to modify, suspend, or rescind the approval if it deems any interim development warrants it.
Based on the OCC’s conditional approval letters issued to the December 2025 batch (Circle, Ripple, BitGo, Paxos, Fidelity Digital Assets), the preopening checklist for a de novo national trust bank typically includes:
- Hiring key officers. The bank must appoint and submit background information to the OCC for all senior executive officers, including the Chief Compliance Officer, Bank Secrecy Act Officer, Chief Technology Officer, Chief Information Security Officer, Chief Trust Officer, and any designated fiduciary officers. This reporting obligation continues throughout the in-organization period.
- IT and operations architecture. The bank must submit a complete description of its final information systems, operations architecture, and an information systems risk assessment and management plan to the OCC’s Novel Bank Supervision Office for review and written determination of no supervisory objection.
- Capital requirements. The bank must maintain capital levels consistent with OCC standards. The Steptoe analysis of the December approvals noted that the OCC accepted relatively standard capital levels, with no requirement for the parent company to enter into a capital and liquidity maintenance agreement.
- AML/KYC compliance. Full compliance with anti-money laundering and know-your-customer obligations must be demonstrated before operations begin, per Buchanan Ingersoll’s analysis.
- Federal Reserve membership. The bank must apply for stock in a Federal Reserve Bank in accordance with 12 USC 222.
- Corporate formation. The bank must adopt Articles of Association and an Organization Certificate and submit them to the OCC’s Chartering, Organization and Structure office. “In Organization” should follow the bank’s name in all official documents, stationery, and advertisements until it opens for business.
Definitive timeline not set, but the clock starts now
The OCC has not published a definitive timeline for when conditionally approved firms must complete preopening requirements. However, the Paxos conditional approval letter (a conversion from state trust to national trust bank) set a six-month window: if the conversion is not completed within six months, approval automatically terminates unless the OCC grants an extension.
The OCC stated it “does not grant extensions of the approval period, except under extenuating circumstances, and expects the conversion to occur as soon as possible after approval.”
Whether Crypto.com’s charter — as a de novo rather than a conversion — carries the same six-month deadline is not yet publicly known. The OCC’s conditional approval letters for de novo charters in December did not specify an identical hard cutoff, but the agency’s general posture is that preopening should not drag on indefinitely.
Notably, the Bank Policy Institute responded to the December batch by questioning whether the OCC’s outlined requirements are “appropriately tailored to the activities and risks in which the trust will engage” and called for more public disclosure about the rationale. The American Bankers Association has separately pushed for slower approvals and stricter standards as crypto-native firms gain access to the federal banking perimeter.
The approval letter is a green light to start building, not to open for business. Crypto.com still needs to meet the requirements, and survive the OCC’s review before it gets the keys.
