World Liberty Gets Preliminary OCC Nod for Bank Charter

World Liberty Financial is closer to moving the infrastructure behind USD1 into a related federally supervised trust company, but the bank is not ready to open.
Key Takeaways
- The proposed trust company plans to take over USD1 issuance, redemption and reserve management from BitGo.
- It would not accept insured deposits or handle WLFI tokens.
- The organizers need at least $20 million in tier 1 capital and must open the bank within 18 months.
On August 14, the Office of the Comptroller of the Currency gave preliminary conditional approval to establish World Liberty Trust Company, National Association, in Bay Harbor Islands, Florida.
The OCC letter makes the current status clear by stating:
The OCC has granted preliminary conditional approval only.
The organizers can now form the legal entity and prepare it for operation. Banking activities cannot begin until the company meets the preopening requirements, passes an OCC examination and receives final approval.
USD1 Could Move From BitGo to World Liberty Trust
BitGo Bank & Trust currently serves as the exclusive issuer and custodian of USD1. Once established, World Liberty Trust Company plans to acquire the stablecoin’s reserve assets and associated liabilities from BitGo.
The conversion service would apply only to assets already held in custody. It would not turn the trust company into a general-purpose crypto exchange.
The letter also says USD1 issuance and redemption are expected to be fee-free at launch.
The proposed bank would be wholly owned by WLTC Holdings LLC. According to the OCC, World Liberty Financial LLC and the bank share indirect common owners.
The OCC separately approved the planned transfer of USD1 reserves and liabilities under an exemption available to newly formed banks. If the charter reaches final approval, issuance, reserve management and custody could sit within the same federally supervised institution.
The Charter Would Not Make USD1 an Insured Deposit
World Liberty Trust Company would be a limited-purpose national trust bank, not a conventional bank that accepts federally insured deposits.
The company has committed not to become a bank under the Bank Holding Company Act. It does not plan to become an insured depository institution and currently has no intention of seeking a Federal Reserve master account.
USD1 would therefore remain a payment stablecoin rather than a bank deposit. Its holders would not receive FDIC protection simply because the issuer operates under a national trust charter.
World Liberty joins several crypto firms pursuing national trust bank charters, a structure that places custody and related services under federal supervision without creating a conventional deposit-taking bank.
The charter would change who issues and safeguards USD1. It would not change the token into insured bank money.
WLFI Tokens Are Explicitly Excluded
The approval covers USD1 and digital-asset custody, not World Liberty Financial’s governance token.
The Bank will not issue, custody, or deal in WLFI tokens.
That boundary was relevant to several public objections. The OCC received seven comments from four commenters, including concerns about WLFI purchases, foreign investment and possible conflicts involving President Donald Trump, his family and members of the Witkoff family.
The regulator said career OCC staff reviewed the application under established procedures. It treated questions about WLFI purchases as outside the charter decision because the proposed bank will not handle the token and neither World Liberty Financial, Inc. nor its foreign investors were direct parties to the application.
The approval also includes passivity commitments from three indirect investors: DT Marks SC LLC, StringZ Holdings RSC (DE) LLC and AMGUS LLC.
Those entities agreed not to seek board representation, access material nonpublic information or influence the bank’s pricing, investment, personnel and operating decisions. If an investor holds at least 10% of a voting class, voting rights above 9.9% must be passed to management under a proportional proxy arrangement.
Eric F. Trump signed one of the commitments as president of DT Marks. The restrictions separate financial ownership from control over the bank’s operations; they do not remove the underlying economic interest.
Bank Capital Is Separate From USD1 Reserves
World Liberty Trust Company must maintain at least $20 million in tier 1 capital.
The greater of 50% of that capital or $10 million must be held in eligible liquid assets. The bank must maintain an additional liquidity buffer covering 180 days of operating expenses without counting the same assets twice.
These funds support the trust company itself and are separate from the assets backing USD1. The $20 million figure is not the size of the stablecoin’s reserve pool.
The capital and liquidity conditions will remain in effect during the bank’s first three years. Significant changes to its products, services or risk limits during that period will require 60 days’ notice and written non-objection from the OCC.
The bank must also comply with the GENIUS Act and future implementing rules. The OCC can require it to alter, stop or divest any stablecoin activity that fails to meet those requirements.
Approval Expires If the Bank Misses Its Deadlines
The organizers must raise the required capital within 12 months of the August 14 decision, setting an August 2027 deadline.
The bank must open within 18 months, or by February 2028, unless the OCC grants an extension under exceptional circumstances.
At least 60 days before the intended opening, the organizers must confirm that the conditions have been met and request a preopening examination. The bank also needs an independent auditor, security and information-system plans, and operating controls covering the Bank Secrecy Act, anti-money-laundering requirements and sanctions compliance.
The OCC can modify, suspend or withdraw its approval if the information supporting the decision changes materially.
Until final approval is granted, BitGo remains the issuer and custodian of USD1. The OCC decision gives World Liberty a path to take over that infrastructure, not a bank that is already open.
- Disclaimer: World Liberty Trust Company has received preliminary conditional approval and is not yet authorized to begin operations. Its proposed services and opening timeline remain subject to final OCC approval. This article is for informational purposes only and does not constitute financial or investment advice.









