The Office of the Comptroller of the Currency has returned Zerohash’s application for a national trust bank charter, according to the regulator’s website.
“The OCC may return a filing as materially deficient where it lacks sufficient information for the OCC to make a determination under the applicable statutory or regulatory criteria,” the regulator wrote in a June bulletin.
The bulletin then details circumstances under which applications would be returned, including “failure to furnish required biographical and financial information of individuals and corporate background and financial report for entities, as well as any required information requested by the filing form.”
The OCC also said it may return an application if responses for additional information are insufficient, or if bank organizers “have not demonstrated that all products and services have been defined with particularity, including how they will be operationalized, or have not fully defined the associated governance, risk management and compliance management infrastructure.”
In a statement last week, Zerohash called the application’s return “an administrative process that allows us to refile this month.”
“This approach was taken in coordination with the OCC and is not a substantive decision on the merits of our application, and it does not affect zerohash’s current operations, which continue under our existing regulatory approvals.”
Zerohash has obtained money transmitter and other various licenses in 47 states, Puerto Rico and Washington, D.C., according to its web page.
The cryptocurrency infrastructure provider, which counts Morgan Stanley as a high-profile partner, applied for the trust charter in March.
That application “covered a wide range of digital asset and fiduciary services,” Zerohash said. The company has decided instead to “take a sequenced approach to the authorization of services, with a more focused approval of national trust activities aligned with our intended rollout timeline,” it added.
The OCC did not publicly announce the return of Zerohash’s application, but the action represents a first of its kind for the regulator amid a Trump-era uptick of trust bank charter activity.
U.K. fintech Wise’s application for a national trust bank charter was denied last month when the OCC said organizers didn’t demonstrate “sufficient familiarity” with federal banking laws and regulations. The regulator also echoed state regulators’ concerns related to anti-money laundering compliance.
The OCC this month rejected Dutch neobank Bunq’s application to become a national bank, saying the proposal “presents significant supervisory and compliance concerns.”
By contrast, Zerohash’s application wasn’t rejected; rather, the company said it looks forward “to swift review of the resubmission,” according to its statement.
Neither the OCC nor Zerohash has signaled what triggered the return, though there are a few possibilities.
Zerohash’s filing lists two different executives as “Chief Compliance Officer” in two consecutive bullets, according to a review by Inner City Press.
The first, Adam Berg, is listed as CFO elsewhere in the application, according to the publication. The second, Erik Kiefel, is Zerohash’s deputy chief compliance officer and chief anti-money laundering officer.
A job listing for a global chief compliance officer appears on Zerohash’s website.
One former holder of that role sued Zerohash in California’s Alameda County Superior Court in February 2025, alleging wrongful termination.
Edgar Guerra, a former Federal Reserve examiner whom Zerohash hired in 2022, allegedly brought more than 250 compliance issues to the company's board in a report responding to New York Department of Financial Services inquiries after crypto exchange FTX failed. Some of the shortcomings, including AML-related ones, had previously been noted and insufficiently remedied, Guerra argued, adding that he was fired in 2023 in part to mask those findings.
Guerra’s predecessor as compliance chief, Stephen Gardner, is now Zerohash’s chief legal officer, co-president and the executive listed as the pending trust bank's CEO.
Morgan Stanley offers crypto trading on its E*Trade platform through its partnership with Zerohash. That bank obtained conditional approval for its own trust charter in June from the OCC.
