In brief
- Catena Labs, Inc. says it is “not a bank” or money transmitter; its account terms cover non-custodial crypto accounts supported by Turnkey Global, Inc., while for dollars it points only to unnamed “regulated partners”.
- Catena Trust Bank, N.A. has only preliminary conditional OCC approval (18 September 2026), which expires unless its capital is raised by 18 September 2027 and the bank opens by 18 March 2028.
- No licence could be tied to the dollar accounts, Catena’s FinCEN registration could not be confirmed, and its state money-transmitter status could not be verified.
Reader question: if my AI agents hold and move money through Catena today, which entity holds the funds, under what licence, and what changes once the trust bank opens?
Catena Labs, founded by Circle co-founder Sean Neville and Matt Venables, lets businesses give AI agents money under human-set rules: identity, spending policies, approvals, an audit trail, accounts and payments. Access has been invite-only since May 2026. Its blog calls this a “banking platform” with “dollar accounts”; its terms say it is not a bank.
Entity and authority
| Entity | Role today | Status (30 Sep 2026) |
|---|---|---|
| Catena Labs, Inc. (Delaware) | Contracting party | Terms: not a “money services business, money transmitter”. FinCEN MSB registration could not be confirmed; state licences could not be verified. |
| Turnkey Global, Inc. | Named provider for non-custodial accounts | Company-reported; Turnkey’s status not yet verified |
| Unnamed “regulated partners” | Not stated | Not publicly disclosed |
| Catena Trust Bank, N.A. (In Organization), New York | Proposed wholly owned subsidiary | Preliminary conditional approval only; not open |
So who holds the funds? Only partly answerable. For the digital-asset “Catena Accounts” in the account terms, “Catena does not provide custody” and beneficial ownership stays with the customer. Keys are generated and stored in a trusted execution environment, and a transfer needs Catena plus at least one user the customer authorises. Digital assets carry no FDIC or SIPC protection. But Catena also refers to “Catena-provided accounts” alongside non-custodial ones, and says Arc customers hold USDC “in their Catena accounts” without saying which kind. For dollars, Catena cites only “regulated partners”. Which partner, under what licence, and whether dollar balances carry deposit insurance: not publicly disclosed (terms, account terms, About, homepage, three blog posts).
Capability map
| Capability | Status (per Catena unless stated) | Performed today by | Evidence |
|---|---|---|---|
| Agent identity, policies, approvals, audit trail | Invite-only; Fortune separately reported invite-only access (May 2026) | Catena Labs, Inc. | 14-20 May 2026 |
| Non-custodial crypto accounts | Offered under account terms; production use company-reported, not tested | Catena Labs, Inc. with Turnkey Global, Inc. | Terms, 8 Jul 2026 |
| Dollar accounts; x402 payments, Catena “handles the conversion” | Used by “early customers” | Dollar-account provider not named | 4 Aug 2026 |
| Fiat to USDC, held and sent on Arc mainnet | Launched, per Catena | Catena accounts; partner and custody path undisclosed | 16 Sep 2026 |
| Cards, ACH, wires | Marketed; live status not stated | Not disclosed | Homepage, 30 Sep 2026 |
| Yield on idle cash | “Yield generation” among services “select businesses” use | Not disclosed | 14 May 2026 |
| Governance of third-party accounts | Announced for “the coming months” | Catena Labs, Inc. | 14 May 2026 |
| Protection for agent payments | Announced (“More on that soon”) | Not disclosed | 16 Sep 2026 |
| Custody, investment management, trust, conversion and clearing | Charter-dependent | Catena Trust Bank, once open | OCC letter p.2; Catena, 20 Sep 2026 |
| Payment stablecoins | Charter-dependent | Catena Trust Bank, once open | OCC letter only |
Stablecoins appear only in the OCC letter: proposed activities include payment stablecoins “that will comply with the GENIUS Act“, and condition 2 makes the bank “conform, cease, or divest” its “stablecoin issuance and redemption activities” if needed. Whether Catena will issue its own coin is not publicly disclosed.
OCC charter timeline
| Date | Step | Source |
|---|---|---|
| May 2026 | Charter application filed | Catena; American Banker |
| 18 Sep 2026 | Preliminary conditional approval, Corporate Decision #1392 | OCC |
| By 18 Sep 2027 | Capital raised, or approval expires | OCC p.9 |
| 60+ days before opening | Letter requesting a preopening examination | OCC condition 11 |
| By 18 Mar 2028 | Bank open, or approval expires; the OCC is “opposed to granting extensions” | OCC p.9 |
Separately, condition 4 requires the bank to maintain at least US$10 million in tier 1 capital, with the greater of 50% of it or US$5 million in eligible liquid assets. Until final approval the bank “may not begin the business of banking”; once open it is limited to trust-company operations. The letter does not state whether the bank will carry deposit insurance: not yet verified (FDIC register not consulted). Neither source says whether today’s dollar accounts would move into the bank.
Product scope and eligibility
Customers must be businesses or people “acting for business or commercial purposes”. Sanctioned jurisdictions are excluded, and Catena “may deny, condition, or restrict access to the Services in any jurisdiction”. It “may require” KYC or “know your business”, beneficial-ownership and other onboarding checks, set partly by its service providers; the actual criteria are not published. Catena makes “commercially reasonable efforts” to enforce customer policies but “does not guarantee” it.
Dependencies
Turnkey supports the non-custodial accounts. If Catena or a provider “goes offline”, customers “could lose control of and access to” assets; the terms make them responsible for independent key access, “including through Private Key Export where available” (background: how exchange hacks happen and what protects users).
Charter peers and a product alternative
Bastion Platforms and Agora won OCC approval in the same batch. Figures are as American Banker reported them (22 September 2026); decision letters not checked.
| Point | Catena | Bastion | Agora |
|---|---|---|---|
| Starting point | De novo charter | Converting its NYDFS limited purpose trust charter (February 2025) | De novo |
| Reported capital requirement | US$10 million | US$6 million | US$10 million |
| Stablecoin role | In OCC letter only | White-label partner (e.g. Sony Bank) | Plans to move AUSD issuance from Agora Bermuda Limited, reported as BMA-licensed, to the bank |
American Banker describes neither as an agent-payments product and we did not check their agent tools, so they are charter peers, not substitutes. Closer on product is Fireblocks Agent Wallets (launched 20 May 2026, “request access”): fintechs issue wallets users delegate to agents, with MPC key management and policy rules for “spend limits, merchant allowlists, time windows”. Fireblocks sells that infrastructure to fintechs; Catena contracts with businesses directly and also markets dollar accounts. Neither’s controls were tested; no second product alternative was checked.
Limitations and unknowns
- How a “banking platform” with “dollar accounts” fits “not a bank”: depends on the partner structure, not publicly disclosed.
- FinCEN MSB registration: search on 30 September 2026 returned no result table; not yet verified.
- State money-transmitter licences: not yet verified; NMLS Consumer Access not consulted.
- Onboarding criteria, card eligibility, issuer and processor: not publicly disclosed (terms, homepage).
- American Banker calls the US$10 million “working capital”, the OCC tier 1 capital: conflicting evidence; we use the OCC’s wording.
- Series A date, 14 or 20 May 2026: conflicting evidence.
- Customers: only unnamed “select businesses”; no named or independently verified one found (blog, About, press page, Fortune). Pricing, eligible countries: not publicly disclosed (terms).
- USDC custody path on Arc, capital raised, Delaware file details: not yet verified.
Key facts (as of 30 September 2026)
- Funding: US$48 million, incl. a US$30 million Series A led by a16z crypto and Acrew
Sources
- OCC: Corporate Decision #1392
- Catena: Terms of Service, Account Terms, About, x402 post, Arc post
- FinCEN: MSB Registrant Search
- American Banker: OCC trust charters
- Fortune: Series A
Last updated: 30 September 2026. Next recheck triggered by: OCC final approval, opening or lapse of Catena Trust Bank; changed terms or providers; the end of invite-only access.
