Paxos Files New OCC Bank Charter Application — A First Step Toward GENIUS Act Stablecoin Issuance
Paxos Trust Company has officially filed a new application with the U.S. Office of the Comptroller of the Currency (OCC) to obtain a federal bank charter, signaling its ambition to become one of the first fully GENIUS Act-compliant stablecoin issuers. This filing marks Paxos’ return to the OCC process after its earlier 2020 national trust bank application, which received conditional approval but later expired in 2023.
The application comes amid a wave of similar moves from major players in the digital asset space. Just last month, stablecoin firm Circle (CRCL.N) and crypto firm Ripple also submitted applications for national trust bank charters, reflecting an industry-wide push to align with the new regulatory landscape established by the Guiding and Establishing National Innovation for U.S. Stablecoins Act of 2025 (GENIUS Act).
The two-step process for GENIUS Act stablecoin launch
Under the GENIUS Act, issuing a compliant USD-pegged stablecoin involves two distinct regulatory approvals:
Step 1 — Obtain a bank charter from the OCC
The first requirement is to secure a federal charter, most commonly a National Trust Bank Charter from the OCC for non-deposit-taking stablecoin issuers.
What it is: A legal status that transforms the issuer into a federally regulated financial institution with the authority to hold reserves, redeem stablecoins, and operate under OCC supervision.
Why it matters: Without this charter, an entity cannot qualify as a “Permitted Payment Stablecoin Issuer” under the GENIUS Act. The charter also preempts the need for dozens of separate state money transmitter licenses, enabling nationwide issuance under a single supervisory framework.
What the OCC looks for: A detailed business plan, robust governance, experienced management, clear compliance and risk frameworks, secure technical infrastructure, and capital adequacy to meet operational demands. The OCC reviews these against safety and soundness standards, much like a traditional bank.
Step 2 — Apply for GENIUS Act stablecoin issuer approval
Once the charter is granted, the issuer must separately (or concurrently) obtain GENIUS Act approval from its primary regulator, in Paxos’ case, the OCC.
What it is: A specialized license confirming that the issuer meets all GENIUS Act mandates, including strict reserve composition, monthly public attestations, redemption rights at par, and robust consumer protection disclosures.
Why it matters: This step legally designates the institution as a Federal Qualified Payment Stablecoin Issuer, allowing it to launch its stablecoin into the U.S. market without being regulated as a security or commodity.
Integrated process: In practice, many applicants, including Paxos, are expected to integrate GENIUS Act requirements into their charter application so both approvals can be coordinated.
Why the bank charter is the critical first step
The bank charter is the regulatory anchor for GENIUS Act compliance. It:
Confers federal legitimacy — OCC-chartered issuers are supervised under the National Bank Act and must adhere to ongoing prudential standards.
Authorizes core activities — Issuing and redeeming stablecoins, holding reserves, and providing custody are recognized as permissible trust banking activities under the Act.
Establishes consumer protections — OCC oversight enforces the GENIUS Act’s protections, such as bankruptcy-remote reserves, no-interest mandates, and transparent redemption processes.
Streamlines national operations — A federal charter removes the operational friction of 50-state licensing and aligns the issuer with one primary regulator.
Without this foundational approval, the GENIUS Act’s second step — stablecoin issuer licensing — is legally inaccessible.
Implications of Paxos’ filing
Paxos’ new OCC application positions it at the forefront of the GENIUS Act era. If approved, Paxos would have the authority to:
Launch a GENIUS-compliant USD stablecoin with national reach.
Compete directly with both existing bank-issued stablecoins and fintech entrants pursuing the same two-step approval path.
Offer institutional and retail clients the assurance of OCC oversight and statutory redemption rights.
With Circle and Ripple also pursuing national trust bank charters, the OCC now faces a queue of high-profile applicants vying to be among the first federally chartered stablecoin issuers under the GENIUS Act. This convergence of filings underscores a reality that every serious U.S. stablecoin issuer must now face: the path to market runs through the OCC, and the GENIUS Act makes that path non-negotiable.