OCC Conditionally Approves Anchorage’s National Crypto Trust Bank

The Office of the Comptroller of the Currency conditionally approved Anchorage Trust Company’s conversion into Anchorage Digital Bank, National Association, on January 13, 2021, placing a cryptocurrency-focused custodian inside the U.S. national banking system.

The decision was consequential because it gave a crypto-native institution a federal trust-bank pathway rather than merely recognizing a digital-asset activity that an existing bank could perform. Contemporaneous reporting described Anchorage as the first cryptocurrency company to receive a U.S. national trust bank charter. The precise development, however, was a conditional conversion approval—not permission to operate as an ordinary deposit-taking commercial bank without restrictions.

What the OCC authorized

Anchorage Trust Company was already a non-depository public trust company organized under South Dakota law. The OCC concluded that its conversion satisfied the applicable requirements of federal law and authorized the resulting national bank to exercise fiduciary powers from its Sioux Falls office and through the internet on a nationwide basis.

The approval letter identified the company’s existing core activities as fiduciary custody of digital assets, custody of client cash through an insured bank acting as sub-custodian, on-chain governance services, staking services and transaction settlement. The digital assets named in the OCC record included Bitcoin, Bitcoin Cash, Ethereum, Zcash and Filecoin. That list described assets Anchorage was serving; it was not an OCC endorsement of those assets or a general authorization for unrestricted cryptocurrency trading.

The structure mattered for institutions because custody, governance participation, staking and settlement could now be delivered through a nationally chartered trust institution subject to OCC examination. Anchorage separately asserted that its charter and fiduciary powers would resolve qualified-custodian questions for institutional clients. That was the company’s contemporaneous legal position, not a blanket determination by the OCC covering every asset, client or securities-law obligation.

A bank charter with narrow boundaries

The approval did not turn Anchorage into a conventional retail bank. The OCC required Anchorage Digital Bank to limit its business to trust-company operations and related or incidental activities. It could not engage in activities that would make it a “bank” under Section 2(c) of the Bank Holding Company Act. Client cash was to remain at a separately chartered, Federal Deposit Insurance Corporation-insured sub-custodian; the record did not say that cryptocurrency held by Anchorage carried FDIC insurance.

Several requirements also had to be completed before the conversion became effective, including adequate fidelity-bond coverage, an application for Federal Reserve System membership, other required regulatory approvals and qualifying shares for directors. The OCC’s letter said a separate completion acknowledgment would officially authorize commencement of business as a national bank. Accordingly, the verified January 13 event is the conditional approval itself, not an independently established opening date.

Supervision was part of the bargain

An enforceable operating agreement imposed detailed capital, liquidity, governance, cybersecurity and compliance obligations. Anchorage had to maintain Tier 1 capital equal to at least the greatest of the amount required to be well-capitalized, $7 million or a higher amount required by the OCC. At least 50% of its basic capital requirement had to consist of eligible liquid assets. Separately, it had to maintain eligible liquidity equal to at least the greater of $3 million or 180 days of qualifying operating expenses.

The agreement also required programs addressing Bank Secrecy Act and anti-money-laundering compliance, sanctions screening, unhosted-wallet risk, transaction monitoring, information security, independent auditing and third-party relationships. Those conditions show why the January 13 decision was institutionally important: federal recognition arrived together with an explicit supervisory perimeter for crypto custody and protocol-facing services.

No causal market-price conclusion can be drawn from the charter records. This reconstruction therefore makes no claim that the approval moved Bitcoin or any other digital asset during a particular trading window.