Conditional Approval Under OCC Decision 1391

Stablecoin infrastructure provider Bastion has received conditional approval from the Office of the Comptroller of the Currency (OCC), the Treasury bureau that charters and supervises national banks, to convert its New York-chartered trust company into a national trust bank, according to the regulator's chartering document (Decision 1391). Once the remaining conditions are met, the restructured entity — Bastion Platforms National Trust Company — will conduct issuance, custody and transfer of dollar-pegged tokens under a single federally supervised roof, moving USDC-style stablecoin rails closer to recognized banking infrastructure.

Per the OCC's Decision 1391, Bastion filed its conversion application on March 30, 2026, under license number 27198, with a principal office at 216 Bowery in New York City. The regulator also approved an exemption from the citizenship requirement for one board member.

The approved activities span stablecoin custody wallets, fiat-to-USDC conversion for custody customers, and support for other regulated stablecoin issuers, including white-label issuance under third-party brands — an arrangement that lets companies deploy dollar token programs without building the full stack themselves. Bastion does not issue a stablecoin of its own and has partnered with Sony's banking.

Federal Supervision and Charter Limits

Chief executive Nassim Eddequiouaq framed the approval as recognition that stablecoins have matured from an emerging technology into core financial infrastructure, demanding new standards of trust, governance and regulatory rigor. The company has pursued federal supervision since acquiring its New York trust charter in February 2025 and has added four board members and advisors with backgrounds at American Express, Morgan Stanley, Ernst & Young and Optim.

The charter's limits matter as much as its scope. Those constraints follow from the charter type itself: national trust companies are built around fiduciary and custody powers rather than a commercial bank's deposit-taking franchise. Per the OCC, the national trust company cannot accept deposits, will not carry FDIC insurance, must buy shares in a Federal Reserve member bank before opening for business, and receives no automatic access to Federal Reserve payment systems. In its determination, the regulator concluded that custody, transfer, stablecoin issuance and issuer services are permissible trust company activities under federal banking law.

Bastion's financial runway comes from an equity round rather than a token-sale SAFT. The company raised $14.6 million in a round led by Coinbase Ventures, with participation from Sony, the investment subsidiary of Samsung, Andreessen Horowitz and Hashed — a roster showing how far Asia's technology groups now reach into US regulated custody.

A Crowded Trust Charter Race

Bastion enters a queue that has swollen under the GENIUS Act. Comptroller Jonathan Gould said in August that the OCC had received roughly 40 applications for new bank charters over about 18 months, 23 of them tied to digital-asset activity — an eight-fold increase compared with the four preceding years. Circle secured final approval for Circle National Trust on July 10 after a conditional nod in December 2025, while BitGo, Fidelity Digital Assets and Paxos also won conditional approvals that December. Ripple holds conditional approval for a similar charter, and Kraken parent Payward, infrastructure provider Zerohash and Jack Dorsey's Block have filed applications of their own.

The pace of charters has drawn political fire. In a May 18 letter to Gould, Senator Elizabeth Warren argued that the OCC had already approved at least nine national licenses for crypto firms and that some planned activities exceed trust company powers; in her words, these firms are "effectively digital-currency banks seeking to sidestep the guarantees that accompany banking."

Macro implications are stacking up as well. Researchers at Brookings put the stablecoin market at roughly $270 billion as of June 2026, spanning payment-focused dollar tokens to yield-bearing DeFi instruments like Savings Dai (sDAI), and the Bank for International Settlements warned in August that wider adoption of dollar-linked tokens could accelerate digital dollarization. For custody customers weighing bank-style charters against exchange venues, federal charters are reshaping the available options, though activities such as margin trading remain outside the trust charter's permitted scope.

GENIUS Act Sets the Clock

The primary texts matter more than the press releases here. The GENIUS Act, enacted July 18, 2025, is the framework statute, and the OCC's February rule proposal — covering reserve assets, redemption, custody, risk management and issuer supervision — fills in the operating details, with Gould expecting a final rule by November. Decision 1391 itself states the binding test: Bastion's custody, transfer, issuance and issuer-support services are lawful trust company activities.

The approval remains conditional, not final. The outstanding OCC conditions, the required Federal Reserve member bank share purchase, and the absence of FDIC insurance or automatic Fed payment access all still apply, making the federal charter a supervised starting point rather than full banking status.