When Jonathan V. Gould, Comptroller of the Currency of the Office of the Comptroller of the Currency announced a preliminary conditional approval on , the banking world took notice. The approval went to Erebor Bank, National Association, a digital‑native institution headquartered in Columbus, Ohio with a planned secondary hub in New York City. Founded by tech entrepreneurs Palmer Luckey of Anduril Industries and Joe Lonsdale of Palantir Technologies, the bank is backed by billionaire Peter Thiel. The decision marks the first de novo national‑bank charter granted since Gould took office on July 15, 2025, and it signals a notable shift toward digital asset banking in the United States.
Background and Founders
Erebor Bank entered the OCC’s pipeline on , submitting a comprehensive charter application that emphasized a purely digital operating model. Luckey, 32, is best known for founding Anduril Industries, a defense‑technology firm that has grown into a $2.3 billion enterprise. Lonsdale, 39, co‑created Palantir Technologies, a data‑analytics powerhouse valued at roughly $45 billion. Thiel, 57, co‑founded both Palantir and PayPal, and his involvement lends both capital and credibility to Erebor’s crypto‑focused ambitions.
Regulatory Approval Details
The OCC’s press release noted that the review took 127 days—just shy of its internal 120‑day target, a timeline that had historically been missed on complex fintech cases. Gould told the banking industry, “Today’s decision is proof that the OCC under my leadership does not impose blanket barriers to banks that want to engage in digital asset activities.” He added, “Permissible digital‑asset activities, like any other legally permissible banking activity, have a place in the federal banking system if conducted in a safe and sound manner.”
Industry analyst Brian Graham, partner at the Washington‑based advisory firm Klaros Group, said, “Regulators have a four‑month turnaround requirement, but it’s rarely met. Hitting that window for a crypto‑linked de novo bank shows the OCC is serious about its deadlines.”
- Application filed: June 11, 2025
- Conditional approval: October 16, 2025
- Review length: 127 days vs. 120‑day target
- Primary headquarters: Columbus, Ohio
- Secondary hub: New York City, New York
Industry Reactions
Banking Dive’s coverage highlighted the surprise among fintech firms that a “digital‑native” bank could achieve a charter so quickly. AMBCrypto cautioned that Erebor must still satisfy stringent capitalization, cybersecurity, management expertise, and anti‑money‑laundering (AML) conditions before a full launch. AML Intelligence flagged “key AML concerns” but offered no specifics, underscoring the regulatory tightrope the bank will walk.
Critics worry that a bank heavily tied to cryptocurrency could attract illicit flows, yet proponents argue that a regulated bank could bring much‑needed compliance infrastructure to a sector that has traditionally operated in the shadows.
Implications for Digital‑Asset Banking
The OCC’s move represents a departure from the cautious stance of previous administrations, which often placed “protective walls” around traditional banks seeking crypto exposure. By granting a conditional charter, the OCC is effectively saying that regulated banks can serve crypto firms—as long as they meet safety standards. This could open the floodgates for other fintech startups eager for a banking partner that understands digital assets.
For cryptocurrency exchanges, blockchain‑based payment processors, and AI‑driven trading platforms, Erebor’s approval offers a potential “home‑grown” banking solution that avoids the patchwork of third‑party correspondent accounts that have been the norm since the 2022 market crash.
Next Steps and Timeline
Erebor now faces a checklist of conditions before the OCC can issue a final charter. These include:
- Raising a minimum of $500 million in Tier 1 capital.
- Hiring a Chief Risk Officer with at least ten years of banking experience.
- Implementing a multi‑layered cybersecurity framework audited by an external firm.
- Establishing a robust AML program that satisfies the Financial Crimes Enforcement Network (FinCEN) standards.
- Demonstrating ongoing compliance with the OCC’s safety‑and‑soundness metrics.
While the OCC did not set a hard deadline, insiders estimate that meeting these conditions could take anywhere from six to twelve months. If Erebor satisfies them, a final approval could arrive as early as mid‑2026.
Historical Context
Before Gould’s appointment, the OCC had not granted any preliminary conditional approvals to a de novo bank since the agency’s inception in 1863, let alone one focused on digital assets. The 2022 crypto market plunge prompted regulators to tighten scrutiny, and several banks were warned or penalized for lax controls. Gould’s public statement—“I am committed to a dynamic and diverse federal banking system”—signals a strategic pivot aimed at integrating innovative financial services while preserving stability.
Should Erebor succeed, it will join a tiny club of U.S. banks that have built their business model around blockchain and AI, potentially reshaping the competitive landscape for both legacy institutions and emerging fintechs.
Frequently Asked Questions
How does Erebor’s conditional approval affect cryptocurrency firms?
The approval gives crypto firms a regulated banking partner that can hold deposits, issue cards and provide lending services under federal oversight. It may reduce reliance on offshore banks and improve trust among investors, but the firms will still need to meet Erebor’s AML and compliance standards before accessing full services.
What specific conditions must Erebor meet before a final charter?
Erebor must secure at least $500 million in Tier 1 capital, appoint seasoned risk leadership, pass an external cybersecurity audit, implement a comprehensive AML program that satisfies FinCEN, and continuously demonstrate compliance with the OCC’s safety‑and‑soundness metrics.
Who are the key backers behind Erebor Bank?
The venture is co‑founded by Palmer Luckey of Anduril Industries and Joe Lonsdale of Palantir Technologies. Billionaire investor Peter Thiel provides significant capital and strategic guidance.
How does this decision differ from the OCC’s previous stance on crypto‑related banks?
Earlier OCC leadership often imposed “blanket barriers” that prevented banks from engaging in crypto activities. Gould’s statement explicitly rejects such blanket bans, emphasizing a case‑by‑case approach that allows banks to offer digital‑asset services if they demonstrate safety and soundness.
What timeline can we expect for Erebor’s final charter?
While the OCC has not set a firm deadline, industry insiders estimate that satisfying all conditions could take six to twelve months. If everything goes smoothly, a final approval could be announced by mid‑2026.
Write a comment