The next chapter of financial innovation will be shaped by trust and oversight. 

Paxos operated as a trust company under the New York Department of Financial Services (NYDFS) from 2015 through 2025, meeting one of the most rigorous standards for transparency and consumer protection in the digital asset industry. New York set a high bar for prudential regulation over stablecoins, overseeing how digital money is issued and managed and ensuring that the stablecoins we issue are fully backed, transparently managed and independently audited.

In parallel with the passage of the GENIUS Act in the U.S. we converted our state charter into a national trust charter on December 12, 2025. Paxos Trust Company, N.A. is now a national bank limited to the operations of a trust, supervised by the Office of the Comptroller of the Currency (OCC). All of our U.S. activity sits under this federal prudential framework.

What is an OCC Charter?

The Office of the Comptroller of the Currency (OCC) is a bureau within the U.S. Department of the Treasury that charters and supervises national banks and federal trust companies. 

It is the premier federal banking authority in the U.S. and oversees many of the country's largest financial institutions, including JPMorgan Chase, Citi, Bank of America and Wells Fargo. The OCC enforces an expansive set of rules designed to address critical industry and consumer protections, including capital adequacy, risk management and consumer protection. Through its comprehensive examination process and supervisory requirements, the OCC ensures that the largest financial institutions in the U.S. operate in a safe and sound manner. 

An OCC national bank charter also authorizes us to operate on a national basis under federal supervision. For the enterprises that build with Paxos, that means that one integration reaches end users across the country, and compliance teams diligence a single supervisor instead of a patchwork of state licenses.

Statutory regimes for digital assets continue to evolve across the U.S, including in key jurisdictions like California, Illinois and New York. A federal charter puts one consistent standard underneath our partners' products as those regimes develop, so that integration holds as state requirements change.

Why a federal framework matters for stablecoins

Stablecoins are embedded in modern financial infrastructure. They support payments, settlement, trading and onchain financial services. As their role grows, the rules that govern them have to be consistent, enforceable and national in scope.

The GENIUS Act, signed into law in July 2025 and effective January 2027, establishes a federal regulatory framework for payment stablecoins. It requires full backing by high-quality liquid assets, clear and enforceable redemption rights, monthly reserve reporting certified by executives, and an issuer subject to prudential supervision. While these are the standards we have followed since 2015, our conversion to an OCC charter best positions Paxos to continue operating under the highest level of regulatory supervision available under this new regime.

The OCC is the federal supervisory authority designated to oversee stablecoin issuers under the law. Since March 2026, the OCC, alongside other relevant federal regulators, has published proposed rules for operationalizing the requirements under the GENIUS Act, including rules covering reserve composition, liquidity requirements and anti-money-laundering and sanctions obligations.

While the final rules are still pending, and many proposed rules remain to be issued, it is clear that the final rules will require building out a comprehensive reserve and compliance architecture to ensure complete alignment with the GENIUS Act. For us, the charter, reserve structure and audit practices already in place satisfy the proposed requirements.

Not just approved, but fully converted

There are two main forms of OCC charter approval, and it is important to understand the difference when assessing an appropriate counterparty. 

Paxos underwent an OCC conversion process. This means that we took our state chartered trust, which we have operated since 2015, and converted to federal supervision. Our conversion was approved on December 12, 2025 and completed on the same day, and we have been operating under OCC supervision in the U.S. ever since.

By comparison, many in the industry have received conditional approval to stand up a de novo national trust bank: a brand new entity that will be regulated as a national trust bank by the OCC. After receiving conditional approval, these de novo entities will have to create, staff, and build out the infrastructure for the new entity, and then undergo a pre-opening exam, whereby the OCC assesses whether the stood up entity is actually sufficiently established to begin operating as a national trust bank. Only following a successful pre-opening exam will a de novo national trust bank begin operating under OCC supervision. Even then, these firms may face operational challenges. 

A charter and issuing from a charter are two different things

Several digital asset firms now hold OCC charters, or will hold OCC charters soon, but those charters do not all cover the same activities. Some authorize custody, some authorize reserve management, and the entity holding the charter is not always the entity that issues the asset.

That distinction matters if you're evaluating counterparty risk. Ask which legal entity issues the stablecoin, which regulator supervises that entity, and whether the reserves sit inside the same perimeter.

Which entity issues PYUSD and PAXG?

PayPal USD (PYUSD) and Pax Gold (PAXG) are issued by Paxos Trust Company, N.A., the chartered entity itself. Issuance, reserves and custody all sit inside that entity, under OCC supervision.

While we are continuously improving our systems in line with the evolving federal regulatory regime, at its core nothing about how we issue or manage our assets or reserves has changed with the OCC conversion. Reserves continue to be held 1:1 in cash and short-term U.S. Treasuries, segregated from corporate assets, verified monthly and attested by a third-party accounting firm. You can review the current reports on our transparency page.

The key difference is scope. Those protections now operate inside a unified federal regime, with a single supervisor and the bankruptcy-remote protections that come with a national trust structure.

What the charter covers beyond issuance

Our Crypto Brokerage business operates from Paxos Trust Company, N.A., the same chartered entity. Qualified custody, trade execution and settlement for enterprise partners all sit under OCC supervision.

A bank or fintech launching digital asset access often assembles this from separate providers: one for custody, another for execution, another for settlement, each with its own regulator and its own diligence file.

Customer assets are held in segregated, bankruptcy-remote accounts at a federally supervised trust bank. The entity holding those assets is the entity executing and settling the trades, in all 50 states.

The path forward

Federal supervision in the U.S. is one piece of a broader picture. 

We are also supervised by the Monetary Authority of Singapore (MAS) and by the Finnish Financial Supervisory Authority (FIN-FSA) in the EU under MiCA. Enterprises building on our platform receive regulatory coverage that follows them across major markets.

Stablecoins and other digital assets are here to stay, and their role in the financial system keeps expanding. The OCC charter gives that reality the federal supervisory structure it needs.

If you're evaluating what federally regulated stablecoin infrastructure looks like for your business, talk to our team or read more about stablecoin issuance on our platform.