Ripple Gets OCC Approval for National Trust Bank: What It Means for RLUSD
Ripple has received final approval from the U.S. Office of the Comptroller of the Currency to launch a national trust bank, bringing the reserve management and custody of its RLUSD stablecoin under federal supervision. The decision, confirmed by CEO Brad Garlinghouse on 27 October 2026, is one of the most structurally significant regulatory milestones in the U.S. stablecoin market this year, and it creates immediate obligations for accounting firms, auditors, and CFOs whose clients hold or transact in RLUSD. For any team relying on crypto accounting software to track stablecoin positions, understanding what the charter actually permits, and what it does not, is the starting point.
What the OCC Charter Actually Authorises
National trust bank charters occupy a specific and deliberately limited lane in U.S. banking law. They do not permit deposit-taking or lending, and they are legally distinct from full-service commercial bank licences. What they do permit is fiduciary activity: holding assets in trust, managing collateral, and providing custody services under OCC supervision.
The three authorised functions
According to Ripple's public disclosures, Ripple National Trust Bank is authorised to carry out three specific functions:
- Manage the segregated reserves that back RLUSD.
- Act as collateral trustee of those reserves on behalf of RLUSD holders.
- Provide fiduciary digital asset custody services to enterprise clients.
Each of these is a trust-and-fiduciary function, not a banking function in the traditional sense. That distinction matters enormously for how the entity is classified in your clients' books and in any AML/KYC due diligence files.
What remains at the state level
RLUSD issuance will continue to sit with Standard Custody and Trust Company, Ripple's limited purpose trust company regulated by the New York Department of Financial Services. The OCC charter adds a federal supervisory layer on top of existing NYDFS oversight, but it does not consolidate all regulated activity into one entity. The result is a split structure: a federally supervised trustee and reserve manager on one side, and a state-regulated issuer on the other.
Timeline and Competitive Context
Ripple filed its initial application for a U.S. banking licence in July 2025. It received conditional OCC approval less than a year before this final approval was granted. RLUSD itself launched in December 2024 and has grown to a reported market capitalisation of $2.5 billion, with use across Ripple's payment infrastructure and as collateral within Ripple Prime.
A broader wave of OCC approvals
Ripple is not alone in this space. Circle received its OCC conditional approval in July 2026, bringing USDC reserves under federal supervision through a similar national trust structure. Other firms, including Coinbase, Crypto.com, and World Liberty Financial, have received conditional approvals this year. The pattern is clear: the OCC is becoming a primary federal supervisor for the reserve and custody functions of major stablecoin issuers, even as issuance itself continues under state money transmitter and trust company frameworks.
This wave has not been without political friction. Some legislators have argued that granting national trust charters to crypto firms misapplies the National Bank Act and introduces systemic risk. Industry groups have pushed back, noting that national trust charters are confined to fiduciary activities and that firms are voluntarily accepting federal supervision rather than seeking to avoid it. The debate is live, and accounting and compliance teams should monitor it: a legislative reversal, however unlikely in the near term, would materially affect the regulatory standing of these entities.
For context on how OCC supervision failures carry real financial consequences, see our coverage of OCC AML gaps and what they cost AmEx.
Accounting Implications for Firms and CFOs
The structural change Ripple has engineered creates a set of accounting questions that are not hypothetical. If your firm or a client holds RLUSD, you now have two regulated counterparties in the chain: the issuer (Standard Custody and Trust, NYDFS-regulated) and the reserve trustee (Ripple National Trust Bank, OCC-regulated). That bifurcation has direct consequences for how you document, classify, and disclose those positions.
Counterparty classification in the balance sheet
Under U.S. GAAP, stablecoins held by an entity are generally classified as intangible assets or, in some cases, as financial instruments depending on the specific facts and circumstances. The existence of a federally supervised collateral trustee that holds segregated reserves does not, by itself, change the classification of RLUSD in the holder's accounts. What it does change is the quality of the counterparty risk disclosure. A federally regulated trustee is subject to OCC examination, capital requirements (to the extent applicable to trust-only charters), and reporting obligations that a state-only entity is not.
If your digital asset accounting software generates counterparty risk summaries or disclosure schedules, the RLUSD entry should now reflect both entities: issuer and trustee. Legacy workflows that treat a stablecoin as a single-entity exposure will produce incomplete disclosures.
Reserve segregation and audit evidence
The collateral trustee function is particularly relevant for auditors. Ripple National Trust Bank holds reserves in a segregated structure, and RLUSD holders are named beneficiaries of those reserves through the trustee relationship. For an auditor signing off on a client's RLUSD position, the existence of a federally supervised trustee strengthens, but does not replace, the need to obtain direct confirmation of the reserve balance. OCC-supervised entities are subject to examination by the regulator, but that examination is not a substitute for audit evidence obtained independently.
Engagement teams should update their audit procedures to request confirmation from Ripple National Trust Bank as the reserve trustee, not just from Standard Custody and Trust as the issuer. This is a new step that did not exist before the charter was granted.
Enterprise custody services
The charter also permits Ripple National Trust Bank to provide fiduciary digital asset custody to enterprise clients. For any firm or CFO considering using this service, the accounting treatment of digitally custodied assets held by an OCC-supervised trustee should align with the guidance applicable to other fiduciary custodians. Assets held in custody by a third party do not appear on the custodian's balance sheet; they remain on the beneficial owner's books. The federal supervisory status of the custodian does not alter that principle, but it does affect the disclosure of custody arrangements and the due diligence file supporting them.
AML and KYC Obligations: What Changes Now
Federal OCC supervision brings with it a set of AML/KYC obligations that are, in some respects, more prescriptive than those applicable under the NYDFS framework. Ripple National Trust Bank will be subject to the OCC's AML/CFT programme requirements, which include written policies, independent testing, a designated compliance officer, and ongoing training. For firms that rely on RLUSD as part of client payment flows or collateral arrangements, this changes the due diligence calculus.
Customer due diligence on the custodian
If your firm is an accounting practice or audit firm onboarding a client that holds RLUSD in custody with Ripple National Trust Bank, your own AML/KYC procedures should reflect the federally supervised status of the custodian. This does not eliminate your firm's own CDD obligations toward your client, but it does affect the risk rating of the custodian as a counterparty. An OCC-supervised entity carries a materially different risk profile than an unregulated or lightly regulated custodian, and that should be documented in your firm's risk assessment records.
For broader context on how stablecoin arrangements intersect with congressional scrutiny of AML compliance, the background on how the Senate probe into Tether stablecoin lobbying unfolded is instructive reading.
Transaction monitoring for RLUSD flows
The addition of OCC supervision does not change the on-chain nature of RLUSD transfers. Transactions still settle on the XRP Ledger and, depending on integration, potentially other chains. For firms running transaction monitoring on client crypto activity, RLUSD flows should be tagged with updated entity information reflecting the new trustee structure. Monitoring rules that flag stablecoin redemptions or large transfers based on issuer identity may need to be updated to capture the trustee entity as a distinct party in the transaction chain.
Practical Steps for Accounting and Compliance Teams
This development is not a future consideration. The charter is final, and the supervised entity is operational. The following steps are appropriate now.
Update your entity mapping
Any internal database, crypto bookkeeping software configuration, or client record that references RLUSD should be updated to reflect two regulated entities: Standard Custody and Trust Company (issuer, NYDFS) and Ripple National Trust Bank (reserve trustee and custodian, OCC). Document the legal basis for each entity's role and the supervisory authority over each.
Revise audit and assurance procedures
Engagement teams handling clients with RLUSD positions should revise their procedures to include direct confirmation from Ripple National Trust Bank as the reserve trustee. This is new audit evidence that was not previously available or required.
Review custody agreements
Any enterprise using Ripple National Trust Bank for digital asset custody should obtain and review the custody agreement in full. The fiduciary nature of the relationship, the scope of assets covered, and the OCC-mandated terms all affect how the arrangement is documented in the client's financial records and disclosures.
Monitor the legislative debate
The political pushback on OCC crypto trust charters has not resolved. If Congress moves to restrict or reverse the OCC's authority to grant such charters, the supervisory status of these entities could change. Build a monitoring flag into your regulatory update workflow for any legislative action on the National Bank Act as it applies to crypto trust charters.
Frequently Asked Questions
Does Ripple National Trust Bank take deposits or make loans?
No. A national trust bank charter from the OCC authorises only trust and fiduciary activities. It does not permit deposit-taking or lending. The entity is legally and operationally distinct from a full-service commercial bank.
Who issues RLUSD, and does that change under this approval?
RLUSD issuance remains with Standard Custody and Trust Company, Ripple's NYDFS-regulated limited purpose trust company in New York. The OCC charter applies only to the reserve management, collateral trustee, and enterprise custody functions, not to issuance.
How does this affect the accounting treatment of RLUSD on a client's balance sheet?
The classification of RLUSD as an asset in the holder's books does not change automatically. What changes is the counterparty risk profile of the entity managing the reserves. Balance sheet disclosures and counterparty risk assessments should be updated to reflect the bifurcated structure, with the OCC-supervised trustee identified separately from the NYDFS-supervised issuer.
What audit evidence should engagement teams seek for RLUSD positions?
Teams should seek direct confirmation from Ripple National Trust Bank as the reserve trustee, in addition to any confirmation from the issuer. The federally supervised trustee's confirmation of segregated reserve balances is now a distinct and material piece of audit evidence.
Does OCC supervision of the trustee affect a firm's own AML obligations toward clients holding RLUSD?
Not directly, but it is relevant to risk assessment. A firm's own CDD obligations toward its clients remain unchanged. However, the OCC-supervised status of the custodian should be reflected in the counterparty risk rating within the firm's AML risk assessment framework, typically resulting in a lower risk rating than would apply to an unregulated or state-only regulated custodian.
Source: The Block