The Office of the Comptroller of the Currency granted preliminary conditional approval on August 14, 2026, for World Liberty Trust Company, National Association, a proposed uninsured national trust bank in Bay Harbor Islands, Florida. Corporate Decision 1385 is a start-the-clock letter. It is not a live bank.
World Liberty Financial USD (USD1) still has a named exclusive issuer and custodian: BitGo Bank & Trust, National Association. Until the OCC grants final approval and a transfer actually happens, treating Friday’s PDF as in-house USD1 issuance is getting ahead of the paper.
Bitcoin was about $62,985 on the site snapshot fetched at 2026-08-15T00:00:26+00:00, down about 1% over 24 hours. That tape does not change the charter math. The issuer pipe is the story.
What happened
Senior Deputy Comptroller Stephen A. Lybarger signed the decision. The OCC reviewed an application to organize a new national trust bank that would “engage in operations of a trust company and activities related thereto, including fiduciary activities.” Control number: 2026-Charter-344521. Proposed charter number: 25407.
Status is not subtle. “The OCC has granted preliminary conditional approval only.” Final approval and authorization under 12 USC 27(a) to commence business wait on preopening requirements. Until then, the OCC “has the right to modify, suspend, or rescind this preliminary conditional approval should the OCC deem any interim development to warrant such action.”
Proposed work includes dollar-backed stablecoin issuance and redemption and reserve maintenance in a nonfiduciary capacity, digital asset custody as a fiduciary, and conversion services that would let custody customers submit approved stablecoins for USD1. Conversion would be limited to custody customers and to assets already in custody.
The bank would be a wholly owned subsidiary of WLTC Holdings LLC, a Delaware limited liability company. USD1 is described as a core product of World Liberty Financial LLC, a Florida limited liability company. The OCC states that World Liberty Financial LLC and the bank “share indirect common owners.”
Traders will screenshot one sentence. The bank “plans to issue USD1, a fiat currency-backed stablecoin, to institutional clients on a nationwide basis, assuming this role from BitGo Bank & Trust, National Association (BitGo), the current exclusive issuer and custodian for USD1.” After the bank is established, it “intends to acquire and assume USD1 reserve assets and associated liabilities from BitGo.” That is a post-formation plan, not a Friday close.
If capital is not raised within 12 months, or if the bank is not opened within 18 months from the preliminary approval date, “this approval expires.” From August 14, 2026, that is a raise-by window into August 2027 and an open-by window into February 2028. The OCC says it is “opposed” to extensions except in the most extenuating circumstances.
Context
A stablecoin is a token designed to track a reference asset, here the U.S. dollar. Decision 1385 leans on the Guiding and Establishing National Innovation for U.S. Stablecoins Act (the GENIUS Act) to treat payment stablecoins as not deposits under the Federal Deposit Insurance Act, not FDIC-insured, and not something a firm may advertise as federally insured. A federal qualified payment stablecoin issuer can include an uninsured national bank. Condition 2 still requires the bank to conform, cease, or divest stablecoin activities to comply with the GENIUS Act and any implementing rules, in the OCC’s sole discretion.
This is not the first digital-asset trust file in the pile. The letter cites earlier OCC actions, including BitGo’s conversion path, Paxos, Ripple National Trust Bank, and First National Digital Currency Bank. The sequence is familiar: preliminary letter, capital floors, preopening exam, then maybe a final go-live. Circle took a different issuer-wrapper path. Tether’s 2025 KPMG audit was a books story, not a U.S. charter. Different pipes. Same job: who holds the reserve, and who can redeem when the crowd wants out.
DefiLlama’s stablecoin feed showed World Liberty Financial USD (USD1) circulating at about $4.03 billion when we pulled it on 2026-08-15 around 00:16 UTC (peggedUSD 4,025,926,977). Chains on that reading included BSC, Ethereum, Solana, and Tron, among others. A float that size makes an issuer swap an operations event. Counterparty risk sits in the legal name on the reserve, not in the marketing site.
The OCC received seven comments from four commenters, including fights over charter authority, whether issuance is a “deposit,” and conflicts involving President Donald J. Trump and his family, Alexander and Zachary Witkoff, and United Arab Emirati investors in World Liberty Financial, Inc. Career staff, the letter says, reviewed the file under authority delegated by the Comptroller. World Liberty Financial, Inc., “is not a party to this application.” The bank “will not issue, custody, or deal in WLFI tokens.” Passivity commitments from StringZ Holdings RSC (DE) LLC, DT Marks SC LLC, and AMGUS, LLC are attached as an exhibit.
The bank committed not to become a “bank” under the Bank Holding Company Act and, as of the letter, does not plan to seek a Federal Reserve master account. It will not be FDIC-insured. “National trust bank” is not a full-service insured bank with a Fed window.
Capital floors are concrete. Condition 4: at least $20 million of tier 1 capital, with the greater of 50 percent of tier 1 or $10 million in Eligible Liquid Assets, for the first three years. Condition 5: a separate 180 days of operating expenses in Eligible Liquid Assets, not double-counted. Senior hires and board seats during organization and the first three years need OCC no-objection.
The OCC poses no objection to a named slate, including Zachary Witkoff as organizer, director, and president, Robert Witkoff as organizer and director, and Brandi Reynolds as chief compliance officer (the letter’s addressee, at SC Financial Technologies, LLC in Miami). Until opening, “In Organization” must follow the bank’s name on official documents. That is how you tell a pending charter from a live one if the website gets loud.
CoinDesk covered the same OCC letter on August 14. We lead with the PDF. The outlet is a second domain, not the source of the terms.
Our read
I read Decision 1385 as a permission slip with an expiry date, not as a change in who issues USD1 today. Narrative is cheap. The named exclusive issuer on the letter is still BitGo. The live risks are operational: a later asset-and-liability assumption from BitGo, a GENIUS condition that can force cease-or-divest, and an 18-month clock the OCC does not like to extend.
The conflict comments are in the file. The OCC answered with delegated career review and passivity letters. That is the agency’s process claim. It does not move redemption mechanics. Preferential-treatment fears are a supervision story after go-live, not a substitute for the missing final charter.
Fee-free issuance and redemption “at launch,” which the OCC repeats from the business plan, is a promise about a bank that does not exist yet. Price it when organizers request the preopening exam.
Falsifiable claim: By 2026-08-31 23:59 UTC, BitGo Bank & Trust, N.A. remains the exclusive issuer and custodian of USD1 in a World Liberty, BitGo, or OCC primary, because Decision 1385 did not complete that transfer. If a primary dated on or before that deadline states that World Liberty Trust Company, N.A. is already the live exclusive USD1 issuer under a final OCC authorization to commence business, this read is wrong.
What to watch next
Watch the 12-month capital raise and the 18-month opening deadline first. Those are hard stops. A letter at least 60 days before the planned open, telling Chartering, Organization and Structure that conditions are met and requesting a preopening examination, is the next tell that organizers think they are ready.
Watch for a BitGo or World Liberty primary on the reserve-asset assumption. Decision 1385 flags a possible Regulation W issue and grants a new-bank exemption for that purchase in this review. If that transfer prints without a final charter, something is off. If it never prints, USD1 stays a BitGo operational product with a World Liberty brand overlay.
Watch GENIUS implementing rules against Condition 2. The OCC says it has “no indication” the bank will fail to comply. That is not a finished rulebook. A cease-or-divest trigger would matter more than any launch-day fee waiver. For the rest of the issuer stack, keep this letter next to Circle’s Q2 reserve-yield print and the Tether audit note above. Same redemption job. Different wrappers. How to follow crypto news without getting played is the hygiene layer when charter headlines outrun the PDF.