Circle

What is verified today

Register-verified: the French authorisation. REGAFI lists Circle Internet Financial Europe SAS with an Agrément – Établissement de Monnaie Électronique, CIB 17788, SIREN 953990934, LEI 969500OYUDADGZKCR583, head office France, matching the ACPR and RCS numbers Circle publishes.

Name and reference matched, permission not checked: the FCA search for 900480 returned one firm, Circle UK Trading Limited. That establishes which company holds the reference. It does not establish current authorisation status or permission scope; we read the results list and did not open the firm page.

Separately evidenced: the OCC list of active trust banks (as of 31 August 2026) includes charter 25361, First National Digital Currency Bank, National Association, which Circle’s licences page names as Circle National Trust. The NYDFS table of regulated virtual currency entities, read on 23 September 2026, lists Circle Internet Trust Company, LLC d/b/a Circle New York Trust with a Limited Purpose Trust Charter dated 2026-07. We have not established what that charter permits, or whether it bears on USDC issuance; the NYDFS table records the charter type and date and nothing further.

Not verified. The Singapore, Bermuda and Abu Dhabi permissions Circle publishes stay company-reported; we did not search MAS, the Bermuda Monetary Authority or the ADGM FSRA in this pass.

Company-reported. Everything about the token’s terms, the reserves and the redemption routes below, taken from Circle’s own published documents on the dates shown.

Not established. Circle Mint account eligibility, which countries can open one, and whether the reserves are held where and how Circle describes.

Two issuers, and why it matters where you are

USDC is co-issued. Circle Internet Financial, LLC issues it for holders outside the EEA; Circle Internet Financial Europe SAS (“Circle France”) issues it inside the EEA, an arrangement Circle’s terms date from 1 July 2024. The USDC Terms are explicit about their own limits: they “only apply to holders of USDC located outside of the European Economic Area”, and send EEA holders to the MiCA white paper instead.

The redemption policy states the division plainly: “Circle France redeems USDC held by Circle Coins Holders established in the EEA; Circle Coins Holders established outside the EEA exercise their right of redemption of USDC with Circle LLC, under its Circle Mint User Agreement.”

So the token in your wallet is fungible, and the obligation behind it is not. Which set of rules applies to you is decided by where you are established, not by which chain the token is on or who sold it to you.

Outside the EEA: two classes of holder

This is the part worth reading slowly, because the terms split holders into two classes.

The USDC Terms define User Type A as a holder with a Circle Mint account and User Type B as a holder without one, and then say: “For the avoidance of doubt, Users Type B are not customers of Circle, as Users Type B do not have a Circle Mint account.”

The USDC Services (issuing USDC for dollars, redeeming USDC for dollars, and sending and receiving between Mint accounts) are offered to Type A only. For Type B the terms say: “You may not redeem USDC with Circle unless and until you open a Circle Mint account.”

And then the sentence that answers the reader’s question outright:

“if a Holder is not eligible to register a Circle Mint account, or fails to do so, such Holder is not entitled to redeem USDC with Circle.”

Set against that, the same document says Circle “commits to redeem 1 USDC for 1 USD, subject to these Terms, applicable law, and any fees where applicable”, and that USDC “only represents your right to redeem USDC for an equivalent amount of USD through your account with Circle“. The commitment and the condition are in the same document, and the condition is the account.

For a business outside the EEA, the practical consequence is narrower than it first sounds, and worth stating precisely. Under Circle’s published non-EEA terms, a holder without a qualifying Circle Mint account cannot redeem directly with Circle. Whether some other route or legal remedy exists (an intermediary that redeems on your behalf, or a claim arising outside these terms) is something this review has not established, and the terms do not address it. What the document settles is access to the issuer’s own redemption service, not the universe of claims.

Inside the EEA: a statutory right, with conditions

Circle France’s MiCA Redemption Policy, last updated 15 September 2026, starts from a different place: “Pursuant to Article 49 of MiCAR, all Circle Coins Holders have a right of redemption of their Circle Coins at any time and at par value, subject to the conditions set out in the present policy.” Circle presents that as a right arising under the regulation rather than under its own contract, and a statutory entitlement is structurally different from a contractual service. We are relying on Circle’s restatement of Article 49 here; we have not read the regulation’s text against it.

The conditions are still real, and they are not the same for everyone.

The policy also nudges holders elsewhere first: it notes that Circle Coins can be bought and sold on retail exchanges “such as Coinbase, Bitpanda, Bitvavo, Kraken or OKX“, and applies where a holder “has previously attempted to redeem at a retail exchange and has been denied, or specifically wishes to redeem its Circle Coins with Circle France”.

Read the two regimes together and the contrast is sharp. For EEA holders, Circle restates a statutory right, and its policy describes a form-based route for retail holders while expressly requiring a Mint account only for non-retail holders; we have not inspected the form or verified whether its terms create a customer relationship. A non-EEA holder has a contractual commitment whose exercise depends on qualifying for an account. The same token, two different answers to “can I get my dollars back from the issuer”.

One practical limit applies on the EEA side too, and the policy states it: the retail route needs an EEA bank IBAN. An EEA-established individual without one is not obviously served by either path, and the published material does not say what happens then.

Issuer facts

Entity and authority

Two observations. The FCA check adds something Circle’s own disclosure leaves out: the licences page publishes the number but not the company that holds it, and a reader doing diligence needs the name. And the licences page now lists two US trust charters, a New York limited purpose trust company and an OCC-chartered national trust bank; neither listing tells a holder which entity owes them redemption, which the USDC Terms still assign to Circle Internet Financial, LLC.

What backs it, in Circle’s words

The USDC Terms describe reserves as US dollar-denominated assets “held by Circle with U.S. regulated financial institutions in segregated accounts apart from Circle’s corporate funds, on behalf of, and for the benefit of, Users”. Holders get no yield: “you acknowledge that you are not entitled to any interest or other returns earned on such funds.”

Two provisions belong next to that. Circle states it may freeze USDC and “surrender associated USD held in Segregated Accounts” on a legal order from a valid government authority. And where illegal activity is suspected, a holder “may forfeit any rights associated with your USDC, including the ability to redeem USDC for USD”. Segregation describes where the money sits; it does not describe an unconditional right to get it.

The USDC Terms read on 1 October 2026 do not name the institutions or an attestation firm. We have not yet read Circle’s transparency page or attestation reports, so the reserve composition and custodians are not yet verified.

Alternatives

A business that wants a dollar stablecoin it can redeem with the issuer has three close substitutes in this series: the Paxos dollar tokens (USDP, PYUSD, USDG), Agora’s AUSD and Tether’s USDT. Each sits on a different issuer, charter and set of redemption conditions. Every cell below comes from the issuer’s own terms or a register, on the dates given in the sources.

The defensible difference is the EEA. In the documents read for this comparison, only Circle describes a separate route for retail holders, through Circle France, that its policy does not tie to opening an account. The Paxos, Agora and Tether terms we read tie direct redemption to customer status, and Tether publishes the highest entry ticket of the four. For a non-EEA business the four look closer: in each case the issuer owes redemption to its onboarded customers, and everyone else relies on an exchange or intermediary. This review has not checked whether Paxos or Tether publish separate EEA terms.

The Tether profile sets out USDT’s terms, reserves and freeze record in more detail.

Limitations and unknowns

• Circle Mint account eligibility criteria, and the countries in which an account can be opened: not disclosed in the USDC Terms or MiCA Redemption Policy (read 25 September 2026); the Mint onboarding pages not yet verified. This matters because the non-EEA redemption right depends on it.
• Whether a non-EEA holder who cannot open a Mint account has any route to redemption with Circle: not publicly disclosed; the terms say such a holder is not entitled to redeem.
• Minimum amounts, fees or timing commitments on the Circle France retail redemption form: not yet verified; we read the policy, not the form.
• Whether an EEA-established retail holder without an EEA bank IBAN has a redemption route: not disclosed in the MiCA Redemption Policy (read 25 September 2026); the form itself not yet verified.
• AMF confirmation of CASP authorisation E2026-005: not yet verified; the AMF register was not searched in this pass.
• MAS PS20200630, Bermuda DAB 54786 and ADGM FSP 250035: not yet verified; none of those registers was searched in this pass.
• Permission scope behind FCA reference 900480: not yet verified; we matched the name and reference on the results list and did not open the firm page.
• US state money transmitter licences: not yet verified; Circle publishes its own NMLS and state licence documents, which we did not open.
• Reserve composition, custodians and attestation firm: not disclosed in the USDC Terms (read 1 October 2026); Circle’s transparency page and attestation reports not yet verified.
• How Circle Internet Group, Inc. relates to the two issuing entities: not yet verified; only the copyright line was read.
• Paxos and Agora fee schedules, Paxos minimums, and whether Paxos or Tether publish separate EEA redemption terms: not yet verified.
• What the NYDFS trust charter dated July 2026 permits that the group could not do before: not yet verified.
• What the OCC national trust bank (charter 25361) does for USDC, such as reserve custody: not yet verified; Circle’s licences page names the charter but not its role.

Key facts (as of 1 October 2026)

• Subject: Circle, issuer of USDC, examined for who holds a redemption right against which entity
• Issuers: Circle Internet Financial, LLC outside the EEA; Circle Internet Financial Europe SAS inside it, dual issuance dated from 1 July 2024
• Outside the EEA: a holder without a Circle Mint account is “not a customer of Circle”, and a holder ineligible for one “is not entitled to redeem USDC with Circle”
• Inside the EEA: Circle restates an Article 49 MiCAR right to redeem at par at any time; its policy describes a form route for retail holders (EEA IBAN required) and requires non-retail holders who are not existing customers to open a redemption-only Mint account; the form itself not inspected
• France, verified: ACPR electronic money institution, CIB 17788, SIREN 953990934
• UK: FCA reference 900480 resolves to Circle UK Trading Limited; permission scope not checked
• US federal: First National Digital Currency Bank, N.A. (Circle National Trust), OCC national trust bank charter 25361, on the OCC active list as of 31 August 2026; role not established
• New York: Circle Internet Trust Company, LLC listed with a Limited Purpose Trust Charter, 2026-07; scope not established
• Published but unverified here: AMF CASP E2026-005, MAS PS20200630, Bermuda DAB 54786, ADGM FSP 250035
• Reserves: segregated accounts at US regulated institutions, per its terms; no yield to holders; freezable on legal order; custodians and attestor not yet verified
• Deposit insurance: Circle states its Services are not covered by FDIC insurance, SIPC protection or any other federal guarantee, and that it holds no private theft or loss insurance for customers
• Close alternatives: Paxos dollar tokens (PYUSD issued by Paxos Trust Company, N.A. per Paxos; USDP managed by Paxos Trust; USDG jointly managed by Paxos Digital Singapore and Paxos Issuance Europe), Agora’s AUSD (issuer Agora Bermuda Limited) and Tether’s USDT (contracting party Tether International, S.A. de C.V.)
• Website: circle.com