Circle has chartered a New York trust company to issue USDC, but the GENIUS Act’s state-qualified issuer track caps out at $10 billion, and USDC’s supply is roughly seven times that. Circle also holds a separate federal charter, for custody only. Neither Circle nor regulators have addressed how the math is meant to work.
Circle Internet Group announced Friday that Circle Internet Trust Company LLC, doing business as Circle New York Trust, has received a limited-purpose trust charter from the New York Department of Financial Services. It’s the entity Circle’s own OCC filing named as the eventual home for USDC issuance.
Circle has received a limited purpose trust charter from the New York Department of Financial Services for Circle New York Trust.
A meaningful step in strengthening the regulatory foundation behind Circle and USDC.https://t.co/RXX8Hkg1Yu
— Circle (@circle) July 31, 2026
USDC’s circulating supply is running around $72 billion, and the New York trust route Circle just secured sits inside a framework, the GENIUS Act’s state-qualified issuer track, that caps out at $10 billion in outstanding stablecoins before a state regulator’s oversight alone stops being enough, absent a federal waiver. Circle just chartered a vehicle to issue a stablecoin roughly seven times larger than the ceiling that vehicle is built around.
The latest chapter in a regulatory relationship dating back to Circle’s 2015 BitLicense. What the release skips is why issuance is landing in New York at all, given that Circle already holds a second, newly minted federal charter that could plausibly have carried it instead.
On July 29, 2026, Circle acquired IBM’s blockchain patent portfolio, claiming leadership in U.S. blockchain patents. The move strengthens its regulated digital asset and stablecoin strategy.
Custody at the OCC, Issuance at NYDFS
Three weeks earlier, the OCC gave final approval to First National Digital Currency Bank, N.A., operating as Circle National Trust, a national trust bank built for custody, with reserve management pencilled in as a “future capability.”
Its underlying conditional-approval letter, dated December 12, 2025 and later finalized, states plainly, in the OCC’s own words, that “the Bank will not issue stablecoins.” Separately, the charter has also been reported elsewhere as not permitting lending, a detail that letter doesn’t itself address.
That same filing is where Circle first disclosed, almost as an aside, that issuance was always meant to sit somewhere else: a New York limited-purpose trust company. That’s the entity chartered today.
Circle didn’t fold USDC’s regulatory footprint into one shop; it built two, split cleanly along a functional line, custody under the OCC and issuance under NYDFS, which maps directly onto the fork the GENIUS Act itself draws between a federally qualified nonbank issuer and a state-qualified one.
Thirteen Months From Application to Charter
Today’s charter closes out a sequence that traces back, in spirit, to September 2015, when Circle became the first company to hold a New York BitLicense at all:
- September 2015: Circle receives NYDFS’s first-ever BitLicense
- June 2025: Circle applies to the OCC for a national trust bank charter
- December 12, 2025: OCC grants conditional approval
- July 10, 2026: OCC converts it to a full charter (Circle National Trust)
- July 31, 2026: NYDFS charters Circle New York Trust
Eleven years of standing history with the same regulator is a plausible reason Circle went to NYDFS for the issuance leg rather than building a second relationship with the OCC from scratch, but that’s an inference this piece is drawing, not something Circle’s release states.
The $10 Billion Line Nobody’s Addressed
None of this settles the actual math. USDC passed that $10 billion line years ago. Whether Circle plans to operate under continuing federal oversight above it, is counting on a waiver, or is waiting on Treasury’s still-unfinished “substantially similar” certification process to settle the terms isn’t addressed by today’s announcement or by the OCC filing that preceded it.
No public statement from Circle, NYDFS, or Treasury addressing that specific mechanism turned up in the searches run for this piece. Until one of them addresses the $10 billion gap directly, that number, not today’s announcement, is what actually defines the charter’s scope.
FAQ
1. What’s the difference between Circle National Trust and Circle New York Trust?
Circle National Trust is the OCC-chartered federal entity, approved for digital asset custody only; its own approval letter states it “will not issue stablecoins.” Circle New York Trust is the NYDFS-chartered state entity announced today, and the one Circle’s OCC filing named as USDC’s future issuer.
2. Why does a $10 billion cap matter if USDC is worth $72 billion?
The GENIUS Act lets state-chartered issuers operate mainly under state supervision only up to $10 billion in outstanding stablecoins; above that, federal oversight applies unless a waiver is granted. USDC has been well above $10 billion for years, so the cap and USDC’s actual size don’t match up on their face.
3. Has Circle explained how it plans to reconcile that?
Not as of this piece’s publication. No statement from Circle, NYDFS, or Treasury addressing that specific mechanism was found.
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