Author: Zen, PANews
In the U.S. financial regulatory system, the Commissioner of the Currency (OCC) is not the most frequently featured position in the mainstream media headlines, but it is almost always at the forefront of changes in banking rules.
The OCC currently regulates over a thousand banks and related institutions, and the Commissioner himself is also a member of the FDIC (Federal Deposit Insurance Corporation) Board of Directors and the Financial Stability Oversight Council. His judgments not only affect a few banks, but also influence how the U.S. banking system faces risks, innovation, and new technologies.
Jonathan V. Gould, who currently heads this key department that regulates national banks and federal savings institutions, has drawn attention from Wall Street, Silicon Valley, and the crypto industry over the past year due to his distinctive regulatory approach.
Gould does not believe that the banking system should maintain security by excluding new things, nor does he believe that cryptocurrencies should naturally be excluded from the regulated financial system . His core idea is that any activity that is legally permissible and can be carried out under safe and sound conditions should ideally be conducted within the banking system, because only in this way can regulators truly constrain and utilize it.
This also made him one of the most noteworthy and controversial figures in Trump's second term's financial regulatory framework.
From financial legal elites to regulators
Judging from Jonathan V. Gould's career path, he was not a technocrat focused on a single field, but a Washington financial law elite who shuttled between Congress, regulatory agencies, law firms, consulting firms, and financial institutions.
Gould graduated from Princeton University and later earned a law degree from Washington and Lee University. Early in his career, he worked at the law firm Alston & Bird, handling banking regulatory matters. From 2005 to 2008, he worked for the government, serving as legal counsel to the U.S. Senate Committee on Banking, Housing, and Urban Affairs, participating in financial regulatory legislation.
Around the time of the 2008 financial crisis, Gould joined Promontory Financial Group as a director. At this regulatory advisory firm, Gould began directly confronting the survival challenges facing the banking industry after the crisis, exploring how to help financial institutions cope with new regulatory requirements. In 2014, he joined BlackRock Solutions, a subsidiary of asset management giant BlackRock, as an executive, further expanding his knowledge of risk management and financial modeling.
A few years later, in 2018, Gould returned to the Congressional Banking Committee as its chief legal counsel, participating in drafting financial legislation including the 2018 Economic Growth Act. In December of the same year, he joined the OCC as Senior Deputy Oversight Officer and Chief Legal Counsel. The OCC is one of the core regulatory bodies of the U.S. federal banking system, responsible for overseeing national banks, federal savings associations, and some foreign banks' branches in the United States.
Gould's initial experience at the OCC truly catapulted him to fame and made him known throughout the cryptocurrency industry. During this time, he was responsible for the agency's legal and licensing functions, supporting the licensing of new banking business models and providing formal legal advice on the regulatory compliance of digital asset-related businesses. Under his leadership, the OCC also began issuing licenses to innovative banks and released compliance guidelines for certain crypto businesses, such as confirming activities "permissible under safe and robust conditions."
After leaving the OCC, Gould further embraced the crypto industry. He served as Chief Legal Officer at the well-known crypto mining company Bitfury in 2022 , and then joined the law firm Jones Day as a partner in financial markets six months later. In February 2025, Trump nominated Gould to be the Comptroller of the Currency, and he officially took office on July 15, becoming the 32nd Comptroller of the Currency.
More cryptocurrency-friendly regulators
Gould is often perceived as a regulator who is more lenient towards banks and more favorable towards cryptocurrencies. However, this is not accurate. In fact, he opposes vague, spillover, and politicized regulation, not regulation itself.
During his Senate confirmation hearing as Comptroller of the Currency, Gould made two representative statements: one was that banks must be allowed to take “prudent risks”; the other was that since the 2008 crisis, regulators have often tried to eliminate risk rather than manage it, and this shortsightedness affects credit supply, the system’s ability to absorb shocks, and the adoption of new technologies and innovations.
After officially assuming the role of head of the OCC, Gould further institutionalized this approach. He explicitly stated that the OCC should return to a risk-oriented regulatory approach based on law, materiality, and the judgment of auditors. Its focus will be on issues that truly impact safety and robustness, rather than arbitrary checklist-based tools. He also advocated for more predictable and proportionate regulatory tools, while simultaneously promoting the reinstatement of Basel Capital Rules, the modernization of BSA/AML, and targeted burden reduction for community banks.
In March 2025, the OCC issued an explanatory letter reiterating that national banks and federal savings institutions can engage in certain crypto-related activities, including digital asset custody, certain stablecoin activities, and participation in distributed ledger networks, while simultaneously withdrawing the previous, stricter pre-regulatory "no objection" requirement. This move is widely seen as a significant signal that federal banking supervision is reopening the door to crypto businesses.
Gould was clearly not content with merely granting traditional banks limited access to crypto services. His further goal was to provide digital asset companies with a pathway into the federal banking system. During his tenure, the OCC conditionally approved applications from companies like Circle and Ripple to establish or convert into national trust banks. While these licenses do not allow them to accept deposits or issue loans, they do allow companies to conduct asset custody, settlement, and some payment-related business within the federal framework.
Gould made the intentions behind the aforementioned policies very clear at the Blockchain Association Policy Summit at the end of last year. He pointed out that entities engaged in digital assets and other new technology activities should have a path to become federally regulated banks, provided they are willing and meet the OCC licensing requirements. He also emphasized that digital custody should not be treated differently from traditional electronic custody simply because the assets are in digital form; otherwise, the banking system would fall into irrelevant technological discrimination, ultimately causing the system to lose its relevance.
In February of this year, when the OCC released its proposed rules to implement the GENIUS Act, Gould further stated that the OCC had seriously considered a regulatory framework that would allow the stablecoin industry to "thrive in a safe and robust manner." The core of the proposed rules is to formally bring certain payment stablecoin issuers under the OCC's regulatory and enforcement purview, covering bank subsidiaries, federally licensed non-bank issuers, and certain state-licensed issuers, and establishing frameworks for reserves, capital, reporting, and inspection.
The implications of this are significant. It demonstrates that Gould does not view stablecoins as a wild business that should be permanently excluded from the financial system, but rather as a payment tool that can be institutionalized and prudently regulated. More importantly, the OCC's rules are not designed solely for traditional banks; they also explicitly consider non-bank stablecoin issuers who wish to become federally regulated entities. This shows that Gould's openness is not merely a verbal promise, but is reflected in the design of its regulatory framework.
However, the OCC proposal also clearly states that there will be reserve requirements, inspection authority, capital assessment, information reporting, and temporary or encrypted frequency checks when necessary. Furthermore, the OCC reserves the right to conduct inspections outside of normal cycles in emergency situations or in cases of financial stability risk. In other words, Gould consistently supports a licensed, continuously regulated, and inspectable stablecoin ecosystem, not a regulatory vacuum.
Questioned for excessively open regulatory doors
Because of its more open regulatory model, Gould himself has always faced controversy. Critics mainly question him on one issue—is he rebuilding a more modern regulatory framework, or is he making concessions to the crypto industry and some political capital, opening the door too wide?
The criticism mainly comes from two directions. First, from traditional banking. Some banking organizations oppose the OCC issuing national trust bank licenses to crypto companies , arguing that this could allow them to conduct quasi-banking business under less regulation and increase systemic risk. In other words, critics worry that Gould's so-called "innovation access" will ultimately become regulatory arbitrage.
Secondly, there are concerns from the Democratic Party regarding potential conflicts of interest. In February 2026, Elizabeth Warren challenged Gould at a Senate hearing regarding World Liberty Financial, a crypto project backed by the Trump family, applying for a banking license .
While Gould indicated his willingness to consider allowing senior members of Congress to access the application documents confidentially, he emphasized that the license approval process would follow existing procedures, handled by OCC professionals based on publicly available manuals. Facing scrutiny, Gould, with his legal background, was adept at handling the issues. He largely avoided direct verbal battles, repeatedly stressing procedures and rules. However, in the current US political climate, this was insufficient to dispel doubts about regulatory independence.
This questioning also reveals a new division within the US financial regulatory system. Faced with digital assets, stablecoins, and fintech, should regulation lean towards exclusion or inclusion? Gould's answer is clearly the latter. He believes the banking system should not maintain security by isolating itself from reality, but rather by establishing clearer legal boundaries, more targeted risk management, and a more technology-neutral regulatory philosophy to incorporate existing new financial activities into the system.
In this sense, Gould is not simply a "crypto-friendly" figure; he is more like someone who wants to rewrite the relationship between banks and new financial technologies. It's not about abandoning regulation, but changing the starting point of regulation; not about keeping banks away from crypto, but about bringing crypto into banks; not about pretending the risks don't exist, but about acknowledging their existence and then deciding who should manage them.
In the coming years, wherever U.S. crypto policy goes, Jonathan V. Gould will likely be the one that cannot be bypassed.
