In brief
- zerohash’s public payer and payout terms name zerohash llc, a Chicago money transmitter on FinCEN’s list, as the party that receives and sends the funds; which entity signs a fintech’s own platform agreement is not public.
- The OCC lists “zerohash national trust bank” as a pending application, received 19 August 2026; the existing North Carolina trust company says it was cleared to launch in September 2025, but its operations could not be verified.
- zerohash llc claims operating coverage in “51 U.S. jurisdictions”; its licence table lists 49 jurisdictions, a different measure, and no state licence was independently verified.
Reader question: if my fintech routes stablecoin payments or payouts through zerohash, which zerohash entity contracts with me and holds or moves customer funds in my region, under which licence, and what is live versus applied-for?
zerohash (also Zero Hash) sells crypto and stablecoin infrastructure by API to brokers, payment firms and fintechs. Founded in 2017, the group sits under zerohash holdings ltd., backed by Point72 Ventures, Bain Capital Ventures and NYCA. It lists over a dozen legal entities on four continents.
What is verified today
Three facts check out on public registers. ESMA’s interim MiCA register lists zerohash europe B.V. as a crypto-asset service provider authorised by the Dutch AFM on 29 October 2025, passported to 29 other EEA states (background: how ESMA plans to supervise MiCA firms). FinCEN’s money services business list (export of 29 September 2026) has zerohash llc, zerohash liquidity services llc and zerohash trust company llc, each received 16 July 2026. And the OCC’s table of pending digital-asset applications, read on 30 September 2026, shows zerohash national trust bank undecided.
A FinCEN entry is a federal registration, not a state licence. Where a table cell below does not name a register, the licence is as zerohash reports it.
Entity and authority
| Entity | Role in the flow | Licence claimed | Register evidence (30 Sep 2026) | Status and date |
|---|---|---|---|---|
| zerohash llc (Chicago) | Payer terms: receives payments. Payout terms: sender | Money transmitter, “51 U.S. jurisdictions”; NYDFS BitLicense 0000017; NY MT 104418; FINTRAC MSB in Canada | FinCEN: listed (money transmitter, prepaid access, foreign exchange). NYDFS: 403, could not confirm. Other states: not independently checked. FINTRAC: not queried | Company-reported; licence list updated 25 Jun 2026 |
| zerohash liquidity services llc (Chicago) | Settlement provider for zerohash europe transactions | NYDFS BitLicense 0000016 | FinCEN: listed (DE, IL). NYDFS: 403, could not confirm | Company-reported |
| zerohash trust company llc (Asheville, NC) | Company says the charter permits qualified custody (advisers, 401k, IRA) | Non-depository trust company, NC Commissioner of Banks | FinCEN: listed. NC Commissioner register: not queried | Charter 26 Mar 2025, launch clearance 1 Sep 2025 (company-reported); operations not yet verified |
| zerohash national trust bank (proposed) | Would offer custody of digital assets and fiat, settlement, clearing, escrow | OCC national trust bank charter, no FDIC insurance | OCC pending list: listed | Applied for; received 19 Aug 2026 |
| zerohash europe B.V. (Amsterdam) | EU authorised crypto-asset service provider | MiCA CASP (AFM); e-money institution (DNB) | ESMA: CASP listed. DNB register: 403 to our client, EMI could not confirm | CASP 29 Oct 2025; EMI announced 18 May 2026 |
| Stichting Derdengelden zerohash europe | Holds EU clients’ fiat (via unnamed banks) and crypto (omnibus wallets) | None stated | Not checked | Company-reported |
| UK, Australian, Brazilian, Polish, three Bermuda and a second Dutch entity | Not stated in the company documents checked | Not stated | Not checked | Role not publicly disclosed; regulatory status not yet verified |
Under the OCC application, zerohash us llc, owned by the parent, would own the bank, which “will not seek or obtain deposit insurance”. zerohash’s disclosures add that accounts are not covered by FDIC or SIPC.
Product scope and eligibility
zerohash markets stablecoin payouts, payment acceptance and account funding; its account-funding page lists USDC, USDT, PYUSD and RLUSD “and others across 15+ blockchains”. It says payouts reach “more than 200 jurisdictions”, a destination claim, not evidence that a platform in those countries can sign up. For acceptance and payouts, supported assets, networks, the converting party, the asset the recipient receives, onboarding rules and eligible platform countries are all not publicly disclosed. Issuer and reserve checks are not applicable: zerohash moves stablecoins it does not present itself as issuing. The fee disclosure we found covers zerohash europe’s crypto trading services; US or B2B payments pricing was not found in the sources checked.
Where your region lands
US. Under the payer terms, a payer sends stablecoins to Zero Hash LLC, and the payment “will immediately be delivered to, and be the sole property of, the Merchant”. Under the payout terms, a platform instructs Zero Hash LLC to send crypto, and the payout stays the payor’s property until it reaches the recipient. These are end-user terms; they do not show who signs your commercial contract. The US bank holding customer fiat, and whether US crypto sits with zerohash llc or the trust company, are not publicly disclosed.
The homepage says zerohash llc “can operate in 51 U.S. jurisdictions”. Its licence table, updated 25 June 2026, lists 49 by our count: 47 states, DC and Puerto Rico, with no row for California, Hawaii or Montana. These are different measures; the basis for the gap is not yet verified, and a missing row does not prove the service is unavailable.
EU and EEA. zerohash says client fiat and crypto sit with the separate Stichting, which it calls “bankruptcy-remote”, and that settlement comes from the US affiliate zerohash liquidity services llc. The banks behind the Stichting are unnamed.
Everywhere else. No page we read says which entity contracts with platforms in Latin America or Asia-Pacific. For Canada, zerohash llc reports FINTRAC registration; that does not establish product availability there.
Evidence of use
zerohash says it is “now powering partners including Interactive Brokers Europe” in the EU, and lists Morgan Stanley, Stripe and Worldpay among partners, without tying any of them to its stablecoin payment products. On 5 August 2026 zerohash and Visa said Visa Direct stablecoin prefunding and payouts “will become available” to eligible clients: announced, not shown live (compare Citi and Coinbase’s stablecoin checkout). Production use of these payment products by a named customer is not yet verified. Reported Mastercard takeover talks (up to US$2 billion, October 2025) ended in January 2026, per secondary reports.
Alternatives
A regulatory comparison, not a payment-feature one:
| Point | zerohash | Fireblocks | BitGo | Anchorage Digital |
|---|---|---|---|---|
| Federal charter | OCC application pending | None on OCC active (31 Aug) or pending lists | BitGo Bank & Trust, N.A., active | Anchorage Digital Bank, N.A., listed active 31 Aug 2026 |
| MiCA entity on ESMA register | zerohash europe B.V. (AFM) | No match for “Fireblocks”; says it provides no regulated EEA services | BitGo Europe GmbH (BaFin) | No match for “Anchorage” |
| Who is licensed in the flow | zerohash llc named in payer terms | Software; regulated subsidiaries under a separate contract; payment services from partners | Not checked for payments | Bank: custody, settlement. Anchorage Hold, LLC: trading. Payments not checked |
Fireblocks separates its software from regulated subsidiaries and partner-run payments; zerohash names its own entity in the payer terms. BitGo and Anchorage hold the federal trust charter zerohash has only applied for. This compares regulatory structure, not equal payment products.
Limitations and unknowns
- 51 US jurisdictions claimed vs 49 licence rows: different measures, basis not yet verified.
- OCC application: a 4 March 2026 release says zerohash “has applied”; the OCC shows receipt on 19 August 2026 and the public filing is dated 18 August: conflicting evidence, cause unknown.
- EMI licence: company-reported; DNB register returned 403 on 30 September 2026, not yet verified.
- New York complaint address (327 N Aberdeen St) vs corporate address (609 W Randolph St): not yet verified which is current.
- Platform contracting entity, US fiat bank, US pricing, EU banks: not publicly disclosed (terms, disclosures, fee page checked).
Key facts (as of 30 September 2026)
- Parent: zerohash holdings ltd., Chicago; founded 2017
Sources
- OCC: Digital assets licensing applications and the zerohash application
- ESMA: interim MiCA CASP register
- FinCEN: MSB Registrant Search
- zerohash: US licences, corporate structure, payer terms, EU asset segregation, EMI release
- PYMNTS: zerohash exits Mastercard deal
Last updated: 30 September 2026. Next recheck triggered by: an OCC decision on zerohash national trust bank; a change to zerohash’s US licence page or corporate structure; any ESMA or DNB register change for zerohash europe B.V.; a California licence; Visa Direct stablecoin payouts going live; changes to the payer or payout terms or EU custody arrangements.
