The New York State Department of Financial Services issues a limited purpose trust license to Circle: a dual-entity compliance structure for USDC issuance and reserve custody is now in place.
On July 31, 2026, Circle obtained a limited purpose trust license from the NYDFS, and its subsidiary, Circle New York Trust, upgraded from a BitLicense to a trustee regulatory framework. This forms a dual-entity compliance structure with the OCC (Federal Trust Bank), which received approval on July 10—the New York Trust is responsible for USDC issuance, while the Federal Trust Bank is responsible for reserve custody, precisely aligning with the GENIUS Act stablecoin regulatory framework. Circle's global licensing matrix covers major jurisdictions including the US, Europe, the UK, Japan, Singapore, and the Middle East, with a USDC circulation of approximately $77 billion.