SDNY COURTHOUSE, Aug 13 – Zerohash's
application to the Office of the Comptroller of the
Currency to charter a national trust bank — returned by
the OCC on July 17, with the company saying it plans to
resubmit this month — contains an error that Inner City
Press has now confirmed directly from the application
itself: in consecutive bullet points of Section 2(e), the
filing lists two different senior executive officers under
the identical heading "Chief Compliance Officer."
The first: "Chief Compliance Officer: Adam
Berg." Berg is elsewhere in the same application correctly
identified as Chief Financial Officer. The second,
immediately following: "Chief Compliance Officer: Erik
Kiefel. Erik Kiefel is Chief AML Officer and Deputy Chief
Compliance Officer of zerohash" — his own listed title
describing him as deputy to a role the application does
not otherwise show anyone holding.
The application is signed by five
organizers, including proposed CEO Stephen Gardner,
certifying under 18 U.S.C. §§ 1001, 1007, and 1014 that
its contents are "true, correct, and complete." Fair
Finance Watch cites the application in filings with the
OCC on March 11 and May 7.
The confusion did not begin with this
filing. According to a review of the company's own public
disclosures and personnel's professional profiles, Gardner
himself held the Chief Compliance Officer title, alongside
General Counsel, from December 2019 to May 2022 — he is
now Zerohash's Chief Legal Officer, Co-President, and the
person the OCC application proposes as the trust bank's
CEO.
Zerohash then recruited Edgar Guerra,
described as a 25-year compliance veteran and former
Federal Reserve regulator, as CCO and Bank Secrecy Act
Officer in mid-2022; Erik Kiefel joined that fall from
FinCEN, where he had run its Office of Global Liaison, as
Chief AML Officer working under Guerra. Guerra was
terminated February 15, 2023. He has since sued, alleging
in a complaint filed in Alameda County Superior Court that
his firing followed his flagging of more than 200
compliance gaps — a claim this outlet has reviewed
directly in the filed complaint, which brings claims for
wrongful termination, whistleblower retaliation under
California Labor Code § 1102.5, and disability
discrimination, among others, against Zero Hash Holdings,
Zero Hash LLC, and staffing firm TriNet.
No one appears to have publicly carried the
Chief Compliance Officer title at Zerohash since. Kiefel's
own listed title, as recently as this year, remained
"Chief AML Officer and Deputy Chief Compliance Officer" —
precisely the language that appears in the OCC filing
itself, alongside, two lines earlier, a different person
given the title he is nominally deputy to.
And Inner City Press has independently
confirmed that Zerohash is right now advertising for the
position. Want a crypto job?
A "Global Chief Compliance Officer" listing
— live
on the company's own careers page, on Breezy HR, and
syndicated to Ladders, ZipRecruiter, and other job boards
as recently as early July 2026 — describes a role that
will "shape and lead zerohash's global compliance
leadership team," report directly to the Co-President, and
"build and oversee complex programs in a dynamic
growth-minded environment."
The posting's own text confirms what the
corporate structure elsewhere suggests: the Co-President
it would report to is Gardner, the same person who last
publicly held the compliance title himself, more than four
years ago.
Inner City Press has filed a Freedom of
Information Act request with the OCC seeking records
concerning the July return of Zerohash's application, any
records reflecting the agency's consideration of the
company's compliance history, and a list of every national
bank charter application the OCC has returned, as opposed
to formally denied, since January 2025. This as the OCC
attacks the Community Reinvestment, and delays on that
FOIA request by Inner City Press.
Whether the discrepancy in the
application's own management section played any role in
the return is, for now, a question this outlet has asked
the OCC to help answer, not one this article claims to
resolve. What is confirmed, from the document Zerohash's
own organizers certified as complete and accurate: it
names two people to the same job, describes one of them in
his own words as deputy to the role he is also listed as
holding, and the company is now hiring for the position
outright. Watch this site.