Senator Elizabeth Warren (D-MA), the ranking member of the Senate Banking Committee, formally challenged OCC Comptroller Jonathan Gould, a Trump administration appointee, on Tuesday over the agency's conditional approval of national trust bank charters for at least nine crypto firms, including Ripple, Coinbase, Circle, BitGo, Paxos, Fidelity Digital Assets, Bridge (Stripe's stablecoin subsidiary), Protego, and Crypto.com. Warren argues these firms are performing activities that go beyond what the National Bank Act permits for trust institutions, while avoiding the full regulatory requirements that apply to conventional commercial banks.

What the Charters Do and Don't Allow

A national trust charter from the OCC grants a firm federal regulatory status as a trust institution. For crypto companies, this replaces a costly web of state-by-state money transmission and trust licenses with a single federal credential. That credential carries weight with institutional clients such as pension funds and sovereign wealth funds. Crucially, these charters do not permit firms to accept retail deposits or issue loans. Their scope is largely limited to custodying digital assets on behalf of clients. Warren argues, however, that even this delineation is being blurred in practice, with chartered firms already conducting activities she contends exceed those boundaries.

The OCC actively amended its own rules to enable the current wave of approvals. The agency revised 12 CFR 5.20, the rule governing national bank charter applications, replacing the phrase "fiduciary activities" with "operations of a trust company and activities related thereto." That change, which took effect in April 2026, broadened the permissible scope of nationally chartered trust institutions and is the regulatory mechanism underpinning each of the approvals Warren is contesting.

The passage of the GENIUS Act in 2025, which established a federal licensing framework for stablecoin issuers, provided additional legislative tailwind, contributing to the expansion of the global stablecoin market from roughly $180 billion in early 2025 to approximately $323 billion by April 2026.

The OCC issued its first batch of conditional approvals on December 12, 2025, covering Circle (operating as First National Digital Currency Bank), Ripple (Ripple National Trust Bank), BitGo Bank and Trust, Fidelity Digital Assets, and Paxos Trust Company. A second wave followed between February and April 2026, adding Bridge, Protego, Crypto.com, and Coinbase, which received its conditional approval on April 2. In total, eleven companies filed or received approvals within an 83-day window in late 2025 and early 2026. Anchorage Digital, which received its charter in 2021, remains the only fully operational federally chartered crypto trust bank. All others are still in conditional status.

Warren's Argument, Gould's Response

Warren contends the approved firms already conduct crypto trading, payments processing, lending, and stablecoin issuance, activities that exceed the trust bank framework. In a letter to Gould, she argued that these companies act like full-service national banks while evading "the suite of restrictions, safeguards, and obligations" that govern those banks, and that this poses "clear risks to consumers" and threatens the "safety and soundness of the banking system." In Senate Banking Committee statements, Warren also declared that "President Trump's unprecedented crypto corruption has metastasized to the banking system" and that "we have never seen financial conflicts of this magnitude."

This dispute takes place against a backdrop of sharp regulatory reversal. During the Biden administration, the OCC and other bank regulators pursued what critics in the crypto industry called "Operation Chokepoint 2.0," a pattern of informal pressure that made it difficult for crypto firms to maintain access to traditional banking services. Gould's OCC has moved decisively in the opposite direction.

Gould pushed back directly on Warren's characterization. "The only political pressure I have felt from any part of the U.S. government, Senator, is from you," he said. He also argued that Congress requires the OCC to process applications on a timely basis, and framed the agency's current direction as a deliberate break from the prior administration, stating: "Unlike the last four years of the Biden administration, under President Trump's leadership, we are actually doing what we say we will do."

The Independent Community Bankers of America also formally opposed at least one approval, calling Coinbase's conditional charter "a grave mistake."

The WLFI Conflict-of-Interest Question

Warren raised a separate but related concern about World Liberty Financial (WLFI), a crypto firm co-founded by President Trump. She has repeatedly demanded that the OCC halt its review of WLFI's charter application until the President divests from the company. Her concerns center on a reported transaction in which Aryam Investment 1, a UAE entity linked to Sheikh Tahnoon bin Zayed Al Nahyan (the UAE's national security adviser), reportedly purchased a 49% stake in WLFI for $500 million, four days before Trump's inauguration. According to reporting by Decrypt and CoinDesk, approximately $187 million of that investment was reportedly directed to Trump family entities, and approximately $31 million to entities linked to Steve Witkoff. Warren called the OCC's ongoing review of the WLFI application "a sham."

If WLFI ultimately secures a federal charter and the reported stake structure holds, it would mark the first time a Gulf sovereign-linked entity holds a near-majority stake in a US-federally-regulated crypto institution. The implications extend beyond the domestic conflict-of-interest argument. The reported WLFI-UAE investment raises deeper questions about who controls the infrastructure of dollar-denominated crypto settlement for remittance-dependent economies across the Gulf and South Asia, including Pakistan and the Philippines, where stablecoin-based corridors are expanding rapidly.

What This Means Outside the United States

The stakes of this dispute extend well beyond Washington. Following the passage of the GENIUS Act and the federal clarity it provided for stablecoin issuers, the global stablecoin market expanded sharply. It now sits at approximately $323 billion, up from around $180 billion in early 2025, with USDT at $189.6 billion and USDC at $77.6 billion in circulating supply as of April 2026. Stablecoin transaction volume reached roughly $46 trillion in 2025, a 72% year-on-year increase.

For Sub-Saharan Africa, the implications are direct. The region recorded more than $205 billion in on-chain transaction volume in the year to June 2025, a 52% annual increase. Nigeria and Ethiopia both rank among the global top 15 countries for crypto adoption, reflecting deep grassroots demand for dollar-denominated digital assets. Ripple's partnership with Onafriq spans remittance corridors across 27 African countries, connecting over 1,300 mobile wallet endpoints to corridors serving the UK, Australia, and Gulf markets. A federally chartered Ripple entity would provide African banking partners with a more stable US institutional anchor. However, if Warren's legislative and political pressure succeeds in limiting what trust banks may do in payments, it could constrain Ripple's operational model at exactly the moment it is expanding on the continent.

African regulators are also charting their own courses, which may not align neatly with the OCC model. Nigeria's Investments and Securities Act 2025 treats digital assets as securities; while the Central Bank of Nigeria has relaxed restrictions on banks working with licensed crypto providers, the framework diverges from a trust-based custody model. Kenya's Virtual Asset Service Providers Bill, signed in October 2025, creates a separate licensing pathway that may produce regulatory mismatches with federally chartered US institutions operating cross-border corridors. The concern is not merely that US restrictions might limit chartered firms' African operations, but that diverging African regulatory frameworks could compound any constraints imposed at the US end.

In India, the world's largest remittance recipient at roughly $125 billion annually, the institutional credibility attached to OCC charters could accelerate onboarding of payment partners for firms like Coinbase and Ripple. Axis Bank has already tested RippleNet for cross-border corridors, a concrete example of the institutional relationships a federal charter could reinforce. Stablecoin transfers settle at approximately $0.01 to $1.00 per transaction, compared with $25 to $50 per SWIFT wire, and reduced friction at the US regulatory layer matters for correspondent banking relationships. That said, the Reserve Bank of India continues to resist full crypto liberalization, meaning the practical benefits of OCC charter recognition may be constrained by domestic regulatory caution.

South Africa adds another layer of complexity. Draft regulations announced in February 2026 would bring crypto transfers within the South African Reserve Bank's exchange control regime, meaning cross-border stablecoin flows from Circle or Paxos could require explicit regulatory approval going forward. Those regulations remain in draft form and have not yet been enacted.

What Comes Next

The OCC's revised 12 CFR 5.20 rule remains in force, and its replacement of "fiduciary activities" with "operations of a trust company and activities related thereto" continues to serve as the legal basis for the current wave of approvals. Warren's challenges are so far legislative and political rather than legal injunctions, meaning the conditional approvals stand for now. For Ripple specifically, the charter approval carries particular weight following the resolution of its long-running SEC enforcement case in 2025, which removed a major legal overhang and positioned the company to pursue institutional partnerships from a cleaner regulatory standing.

Congressional debate over crypto market structure legislation is ongoing, and Warren has made clear she intends to push for conflict-of-interest guardrails as part of any final bill. Whether her pressure shifts OCC policy or simply frames the 2026 midterm debate around crypto governance remains to be seen.