Circle Wins an NYDFS Limited-Purpose Trust Charter

The New York Department of Financial Services granted a limited-purpose trust charter to Circle Internet Trust Company LLC on July 31, letting the stablecoin issuer run a state-chartered trust company that will do business as Circle New York Trust. Circle said in its announcement that the charter adds state fiduciary and custody powers — the authority to hold and administer assets for other parties under a legal duty of care — to a set of licences it has been assembling since 2015. It is the second charter the company has obtained this month, after a federal one in early July, and the two are held by separate entities answering to separate supervisors. Circle described the network the charter supports as “the world’s largest regulated stablecoin network” and gave no USDC circulation figure alongside the news.

The Charter: Fiduciary Powers Without Deposits or Lending

A limited-purpose trust charter is narrow by design. It authorizes a company to act as a trustee and custodian for other parties’ assets under New York banking supervision, and it does not carry the deposit-taking and lending powers that define a commercial bank. The practical effect for a stablecoin issuer is that custody and fiduciary work can sit inside an entity it owns and a banking regulator examines, rather than with third-party custodians. Jeremy Allaire, Circle’s co-founder, chairman and 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.”

Two Charters: One Federal Examiner and One State Supervisor

The distinction between the two approvals is which government examines the entity and how far its authority reaches. On July 10, First National Digital Currency Bank, N.A., operating as Circle National Trust, received final approval from the Office of the Comptroller of the Currency for a national trust bank, after conditional approval in December 2025 on an application filed on June 30, 2025. That federal charter covers fiduciary digital-asset custody for Circle and its affiliates, potential direct custody for institutional customers such as banks and regulated derivatives organizations, and eventual management of the USDC reserve under federal oversight. The New York charter is granted and examined by the state regulator instead.

The case for holding both is redundancy of permission rather than duplication of function. A national trust bank gives one federal examiner and a footprint that does not depend on qualifying state by state; a New York charter gives fiduciary standing under the supervisor whose rules already govern much of the issuer’s activity in the state. The announcement did not assign the USDC reserve to the state company.

The Stack: What Circle Already Held in New York and Bermuda

The trust charter is an addition to existing permissions, not a replacement for them. Circle listed the following alongside the new charter:

A New York BitLicense, received in 2015, when it became the first company to hold one.
A New York money transmitter licence.
A virtual currency business activity licence.
A digital asset business licence from the Bermuda Monetary Authority.

Each covers a different activity — moving customer money, dealing in virtual currency, operating outside the United States — and none of them conveys trust powers, which is the gap the New York charter closes. One write-up framed the approval against a USDC float of $71.8 billion, a figure the company did not publish itself.

What Is Unresolved: Standing the Entity Up and the Federal Rulebook

A charter is permission to operate, not evidence of operations, and Circle published no timetable for what Circle New York Trust will custody or for whom. The wider stablecoin rulebook is also unfinished: the federal agencies writing implementing regulations under the GENIUS Act still had proposals rather than coordinated final rules on the table through July, with comment periods on identification and anti-money-laundering requirements running into August. Chartered issuers are therefore building compliance around draft text — a different position from the two-year countdown Tether faces to July 2028 before a non-compliant reserve would bar its token from US institutions.