Circle adds a New York trust charter to USDC's regulatory stack
The NYDFS has granted Circle Internet Trust Company a limited purpose trust charter, putting the USDC issuer under the New York Banking Law a decade after it took the first BitLicense.
What happened
The New York State Department of Financial Services granted Circle Internet Trust Company LLC, trading as Circle New York Trust, a limited purpose trust charter on 31 July. CoinDesk reports the charter permits fiduciary, custody and asset-management services under the New York Banking Law. Jeremy Allaire, Circle's chief executive, said that "earning a New York trust charter has been a longstanding objective for Circle given the regulatory clarity that comes with it". Circle was the first company to receive a BitLicense from the same regulator, in 2015.
Why it matters
New York's trust charter is the most demanding state perch available to a stablecoin issuer, and Coinbase, Paxos, BitGo and MoonPay already hold one. What makes this more than another licence is what sits beside it: on 10 July the Office of the Comptroller of the Currency approved First National Digital Currency Bank, N.A., trading as Circle National Trust, for fiduciary digital asset custody. The issuer of the second-largest dollar stablecoin now holds a state trust charter and a national one, which bears directly on which supervised balance sheet the USDC reserve and its custody arrangements finally rest on, and under whose examination.
What is not settled
Circle has not said which activities move into which entity, and its release does not mention the federal approval at all. How a state charter and a national trust bank divide custody, fiduciary work and reserve management between them is unstated, and the two regimes are not identical in what they require. Nor has Circle said whether the reserve, most of which sits in a BlackRock-managed government money market fund, will move to either.
Institutions in this story
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Circle Internet Group, Inc.
Issuer
Now holds a New York limited purpose trust charter through Circle Internet Trust Company LLC, trading as Circle New York Trust, alongside the national trust bank approval the OCC gave on 10 July 2026 for First National Digital Currency Bank, N.A.
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New York State Department of Financial Services
Regulator
Granted the charter on 31 July, adding Circle to the Coinbase, Paxos and BitGo group of limited purpose trust companies it supervises, eleven years after issuing Circle the first BitLicense.
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Office of the Comptroller of the Currency
Regulator
Holds the other half of the question: its 10 July approval covers fiduciary digital asset custody at national level, and neither regulator has said where the reserve work finally sits.
On the record
Circle receives a New York limited purpose trust charter
The New York State Department of Financial Services granted Circle Internet Trust Company LLC, trading as Circle New York Trust, a limited purpose trust charter on 31 July 2026, permitting fiduciary, custody and asset-management services under the New York Banking Law. It sits alongside the national trust bank approval the Office of the Comptroller of the Currency gave Circle on 10 July 2026.