The Office of the Comptroller of the Currency (OCC) has formally returned Zerohash's national trust bank charter application. According to information published on the regulator's official website, the decision has been recorded.

In a notice issued in June, the OCC stated: "When an application lacks sufficient information, making it impossible for the OCC to make a determination under applicable laws or regulatory standards, the OCC may deem the application 'materially incomplete' and return it." The notice further listed circumstances that could lead to an application being returned, including "failure to provide the required biographical and financial information for individuals, or corporate background and financial reports for entities, as well as any necessary information required by the application form."

The OCC also noted that an application may be returned if the applicant's response to a request for supplemental information is inadequate, or if the bank organizers "fail to specifically define all products and services, including how they will operate, or fail to fully define the related governance, risk management, and compliance management frameworks."

Zerohash issued a statement last week saying the return was "an administrative process that allows us to resubmit our application this month." The statement emphasized: "This action was taken in coordination with the OCC and is not a rejection of the merits of our application, nor does it affect Zerohash's current operations—we continue to conduct business under our existing regulatory approvals."

According to information disclosed on Zerohash's official website, the company has obtained money transmission licenses and various other permits in 47 U.S. states, Puerto Rico, and the District of Columbia.

The cryptocurrency infrastructure provider, which counts Morgan Stanley as a notable partner, formally submitted its trust charter application in March. Zerohash stated that the original application "covered a broad range of digital assets and fiduciary services," but the company has now decided to adjust its strategy and instead "adopt a phased approach to service authorization, prioritizing national trust activities aligned with the expected launch timeline."

The OCC did not publicly announce its decision to return Zerohash's application, but this action marks the first such occurrence amid increased activity in trust bank charter applications during the Trump administration.

Last month, the OCC denied British fintech company Wise's national trust bank charter application, citing organizers' failure to demonstrate "adequate familiarity with federal banking laws and regulations," and reiterated state regulators' concerns regarding anti-money laundering compliance. Earlier this month, the OCC also denied Dutch digital bank Bunq's national bank charter application, stating that the proposal "presented significant supervisory and compliance concerns."

Unlike the above cases, Zerohash's application was not denied. The company's statement expressed anticipation of "a prompt review following resubmission."

Currently, neither the OCC nor Zerohash has disclosed the specific reasons for the application's return, but several external speculations exist. According to a review by Inner City Press, Zerohash's application documents listed two different executives as "Chief Compliance Officer" in two consecutive bullet points. Among them, Adam Berg was listed as Chief Financial Officer elsewhere in the application; the other, Erik Kiefel, is Zerohash's Deputy Chief Compliance Officer and Chief Anti-Money Laundering Officer.

Additionally, Zerohash's website still lists a job posting for a "Global Chief Compliance Officer." A former holder of that position filed a lawsuit against Zerohash in February 2025 in the Superior Court of Alameda County, California, alleging wrongful termination.

Edgar Guerra joined Zerohash in 2022 and previously served as a Federal Reserve examiner. Following the collapse of cryptocurrency exchange FTX, Guerra wrote reports in response to inquiries from the New York Department of Financial Services, reportedly raising more than 250 compliance issues to the company's board of directors. Guerra claims that some of these deficiencies (including those related to anti-money laundering) had been previously identified but not adequately remediated, and that he was terminated in 2023, in part to conceal these findings.

Guerra's predecessor as head of compliance, Stephen Gardner, currently serves as Zerohash's Chief Legal Officer and Co-President, and is listed as the CEO-designate of the proposed trust bank.

Morgan Stanley offers cryptocurrency trading through its E*Trade platform, a service that relies on its partnership with Zerohash. Morgan Stanley received conditional approval from the OCC for its own trust charter in June of this year.