To address these limitations, Circle applied to the Office of the Superintendent of the Currency (OCC) in June 2025 to establish a National Trust Bank. This measure is not only a compliance effort, but also a transformation strategy. Many industry observers believe that this marks Circle’s transformation from a simple stablecoin issuer to a comprehensive financial institution. The identity of a trust bank will enable Circle to directly manage reserve custody and asset operations, thereby strengthening internal controls over its own financial infrastructure and expanding digital asset custody services for institutional investors. Circle originated as a native encryption company, but is now adjusting its strategy to build sustainable operations within the existing institutional framework. This involves trade-offs such as reduced flexibility and increased regulatory burden. The scope of authority obtained in the future will depend on policy developments and regulatory interpretations. Nevertheless, this measure marks a crucial milestone in how on chain financial structures can grow and adapt within the existing institutional framework.
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