Crypto Infrastructure Firm Zerohash Applies for OCC National Trust Bank Charter

Zerohash US LLC, a digital asset infrastructure provider, submitted an application to the U.S. Office of the Comptroller of the Currency for a national trust bank charter on March 4, 2026.

The proposed entity, “zerohash national trust bank,” would offer federally regulated digital asset services including custody of digital assets and fiat currency, custodial staking, transfer agent services, stablecoin management, trade execution, and settlement, clearing, and escrow services. Stephen Gardner, the company’s chief legal and compliance officer, has been nominated as the proposed chief executive officer of the trust bank.

Application Details and Proposed Services

The application seeks to establish zerohash as a federally regulated national trust bank, building upon the company’s existing licensing footprint across 51 U.S. jurisdictions and multiple international markets. If approved, the charter would permit zerohash to expand its service offerings under a federal framework, including activities that fall under the GENIUS Act.

The proposed services encompass a comprehensive range of digital asset activities, including custody over digital assets and fiat currency, custodial staking and validation activities, transfer agent services, trade execution, stablecoin management, and settlement, clearing, and escrow services.

The charter would not authorize zerohash to conduct traditional banking activities such as accepting deposits or making loans. Trust banks operate under different regulatory parameters than full-service banks, focusing primarily on custody and asset servicing rather than deposit-taking and lending.

Regulatory Context and Industry Precedent

Zerohash’s application follows a pattern established by several prominent crypto firms seeking federal trust charters since the start of President Donald Trump’s second administration. In December 2025, the OCC offered conditional approval for trust charters requested by Circle Internet Group Inc., Ripple, BitGo Inc., Fidelity’s digital assets arm, and Paxos.

Stephen Gardner, zerohash’s chief legal and compliance officer and proposed CEO of the trust bank, emphasized that stablecoins and digital assets are increasingly becoming part of the core financial system. Applying for a National Trust Bank Charter is a natural next step in offering robust global licensing coverage and continuing to expand the firm’s product offering. The company looks forward to engaging constructively with OCC staff throughout the review process.

Company Background and Client Base

Zerohash provides crypto and stablecoin infrastructure to banks, brokerages, and fintechs, enabling partners to integrate digital asset products through its API and embeddable development kit. The company’s client roster includes major financial institutions such as Morgan Stanley, Interactive Brokers, Stripe, and Franklin Templeton. Prediction markets platform Kalshi is also among its partners.

The company has a significant regulatory footprint globally, operating regulated entities in the European Union, Latin America, Australia, New Zealand, Bermuda, and across 51 U.S. jurisdictions. Zerohash is registered as a money service business with FinCEN and holds money transmitter licenses enabling operations throughout the United States.

In recent months, zerohash added support for the Monad blockchain and USDC on Monad to its crypto infrastructure platform, enabling clients including Kalshi to build and launch stablecoin-based payment flows without running blockchain infrastructure or securing their own regulatory licenses.

Strategic Significance

The application reflects zerohash’s strategy to enhance its regulatory posture as the legislative landscape for stablecoins and digital assets matures. Approval would allow the company to operate under federal supervision, potentially attracting more institutional clients seeking regulated counterparties for digital asset services.

Federal trust charters provide firms with a uniform regulatory framework, reducing the complexity of complying with varying state-level requirements. Some trust charter applicants have also expressed intentions to seek access to Federal Reserve master accounts, which provide direct access to federal payment systems like FedWire. Kraken, a state-chartered Special Purpose Depository Institution, recently announced it had been awarded a limited master account.

The application is now available for public review on the OCC’s website.

FAQ: Zerohash National Trust Bank Charter Application

What services would zerohash’s national trust bank provide?

The proposed trust bank would offer digital asset services including custody of digital assets and fiat currency, custodial staking and validation activities, transfer agent services, trade execution, stablecoin management, and settlement, clearing, and escrow services.

How does a national trust bank differ from a traditional bank?

A national trust bank cannot accept deposits or make loans like a traditional bank. Instead, it focuses on custody, asset servicing, and other specified trust activities while operating under federal supervision. This structure is well-suited for digital asset custody and related services without engaging in traditional banking activities.

What is the significance of this application for zerohash’s clients?

If approved, the charter would allow zerohash to operate under federal supervision, potentially enhancing institutional client confidence and enabling expanded service offerings under a unified federal framework. This follows similar applications by other major crypto firms including Circle, Ripple, and BitGo, all of which received conditional OCC approval in December 2025.