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Circle Internet Financial, LLC is the issuer of USDC. In Circle’s latest disclosed year-end allocation (December 31, 2025), approximately 88% of reserves were in the Circle Reserve Fund, a Rule 2a-7 government money-market fund managed by BlackRock, with the fund’s assets held in custody at BNY. The balance was typically cash in accounts for the benefit of USDC holders, primarily at global systemically important banks (GSIBs), plus a small amount at additional banks.
You can verify that arrangement without relying on a crypto exchange or block explorer: check Circle’s dated Transparency & Stability page, confirm the issuer in Circle’s corporate and regulatory filings, read the latest SEC filing for the fund manager and custody details, inspect BlackRock’s daily USDXX disclosure, and compare the latest independent examination’s circulation and reserve-asset figures.
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The short answer: who issues and holds USDC reserves?
USDC has one issuer: Circle Internet Financial, LLC. Circle entities create USDC when eligible customers provide dollars and redeem USDC for dollars under Circle’s redemption process. The issuer is therefore not the same thing as the investment manager or the custodian.
| Role | Organization or location | What the role means | Evidence date or cadence |
|---|---|---|---|
| Issuer | Circle Internet Financial, LLC | Creates, redeems and administers USDC through Circle entities. | Circle corporate disclosures and SEC filings; confirm the dated filing you use. |
| Investment manager | BlackRock | Manages the Circle Reserve Fund, a Rule 2a-7 government money-market fund. | Approximately 88% allocation reported for December 31, 2025. |
| Custodian for the fund | BNY | Holds the assets inside the Circle Reserve Fund. | Year-end 2025 SEC disclosure; Circle also announced BNY as a primary USDC-reserve custodian on March 31, 2022. |
| Cash banks | Primarily GSIBs, with additional operational banks | Hold the remaining reserve cash in accounts titled for the benefit of USDC holders. | Typically 10–20% in Circle’s 2025 Form 10-K description; the exact mix changes. |
| Assurance provider | An independent Big Four accounting firm | Examines management’s assertion that reserve assets meet or exceed USDC in circulation. | Monthly third-party assurance; use the report’s own “as of” date. |
Circle’s Transparency & Stability page states: “USDC is always redeemable 1:1 for US dollars, and EURC is always redeemable 1:1 for euros. Always.” Treat that as Circle’s stated redemption policy, then use the dated filings and examination reports to check the reserves supporting the policy.
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How to verify the issuer and custodian yourself
Use the sources in this order so that you do not mistake a current circulation number for a current custody statement, or a fund disclosure for a complete reserve report.
1. Start with Circle’s Transparency & Stability page
- Open Circle’s Transparency & Stability page.
- Write down the page’s dated “as of” line before reading the percentages or balances. A transparency page can be updated while older figures remain visible in a linked report.
- Check that the page describes USDC as redeemable 1:1 and publishes circulation, reserve composition, weekly holdings, and mint-and-burn flows.
- Follow the page’s links to the monthly assurance reports. Save the report date, not merely the date on which you downloaded it.
This page is the fastest way to see what Circle currently chooses to disclose, but it is an issuer-controlled source. Its strength is recency and a consolidated view; its limitation is that it does not replace the detailed custody and legal disclosures in a regulatory filing.
2. Confirm the legal issuer
Search Circle’s corporate announcement identifying Circle Internet Financial, LLC as the sole issuer of USDC and confirm the same name in Circle’s SEC filings. “Circle,” a parent company, a distribution partner, a cryptocurrency exchange and a blockchain network can all appear in USDC documentation without being the issuer. The issuer is the Circle entity responsible for minting, redemption and administration.
Record the exact legal name and the document date in your notes. If a wallet or exchange says it “supports USDC,” that describes distribution or custody of your coins, not issuance of the stablecoin or custody of Circle’s off-chain reserves.
3. Read the latest SEC filing for allocation and custody
- Open Circle Internet Group’s latest available Form 10-K or other relevant SEC filing.
- Find the section describing USDC reserves and the Circle Reserve Fund.
- For the position reported at December 31, 2025, note that approximately 88% of USDC reserves were in the Circle Reserve Fund.
- Confirm that the fund is a Rule 2a-7 government money-market fund managed by BlackRock.
- Confirm that the assets held in that fund were in BNY custody.
- Read the separate discussion of cash in FBO accounts. Circle said the remaining 10–20% was typically cash, primarily at GSIBs, with a small fraction at additional banks.
FBO means “for benefit of.” The account title is intended to identify the customers who benefit from the funds rather than treating the cash as an unrestricted corporate operating balance. The filing’s percentages describe a particular reporting position and a typical range, not a permanent allocation. Do not quote the 88% figure as a 2026 percentage unless a newer dated disclosure supports it.
4. Check the fund-level disclosure updated daily
Circle’s filing references BlackRock’s USDXX disclosure for daily fund-level information. Use that disclosure to check the Circle Reserve Fund’s current portfolio and net asset information, then compare its date with Circle’s transparency page and the SEC filing.
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Daily fund data answers a narrower question than a reserve report: it tells you about the assets inside the fund. It does not, by itself, show the cash held in Circle’s FBO accounts or every reserve asset outside the fund. Keep a separate note for the fund’s date, portfolio and custodian information.
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1Clear out junk files and repair common Windows errors2Scan for outdated or missing drivers - takes under a minute3Repair Windows errors before they cause bigger problems5. Retrieve the latest independent examination
- From Circle’s transparency page, open the newest independent examination report available to you.
- Locate the table or assertion containing “USDC In Circulation” and “Fair Value of Assets Held in USDC Reserve.”
- Copy the report date and both figures exactly, including commas and currency symbols.
- Read the accountant’s conclusion and the criteria in the accompanying USDC Reserve Report.
The June 30, 2025 examination reported 61,332,530,506 USDC in circulation and $61,397,784,739 in fair value of assets held in the USDC reserve. The difference was $65,254,233 on that report date. The independent accountant concluded that management’s assertion that reserve assets were equal to or greater than USDC in circulation was fairly stated, in all material respects, under the defined criteria.
6. Compare dates before comparing numbers
A circulation figure from a June examination cannot be compared directly with a reserve percentage from a December Form 10-K as though both describe the same instant. A useful worksheet has one row per document:
| Document | Date to record | Question answered | Scope |
|---|---|---|---|
| Transparency & Stability page | Dated “as of” line | What Circle currently publishes about supply, reserves and flows | Issuer-wide overview |
| SEC filing | Reporting date and filing date | Who manages the fund, who has custody and how cash is distributed | Regulatory description of reserve arrangements |
| USDXX disclosure | Daily update date | What assets are in the Circle Reserve Fund today | Fund level only |
| Independent examination | Report date | Whether examined reserve assets met or exceeded circulation on that date | Defined reserve criteria and assertion |
7. Preserve an evidence trail
Save the document title, publisher, “as of” date, reporting period and the specific page or section where you found each fact. If the next update changes the custodian, fund allocation or cash-bank list, you can tell whether the change is real or simply a difference in reporting date and scope.
What each organization actually does
Circle: issuer and administrator
Circle is responsible for the USDC issuance and redemption mechanism. It receives eligible dollars, creates USDC, processes redemptions and reports circulation and reserve information. That operational responsibility is why Circle’s assertion is the subject of the independent examination.
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One free scan finds every outdated or missing driver and matches the right update for your exact hardware.Free scan · exact hardware matchIssuance does not mean Circle personally holds every dollar in a bank account. Circle can place qualifying assets in a money-market fund and maintain cash at several banks while remaining the issuer.
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BlackRock: investment manager, not the issuer
BlackRock manages the Circle Reserve Fund. The fund is structured as a Rule 2a-7 government money-market fund, which limits its permitted investments and imposes money-market-fund requirements. BlackRock’s management role means it selects and administers the fund’s investments under that fund’s rules; it does not mean BlackRock issues USDC or guarantees redemption of every token.
BNY: custodian for assets in the fund
BNY holds the assets inside the Circle Reserve Fund. Circle’s March 31, 2022 announcement described BNY as a primary custodian for USDC reserves. “Primary custodian” should not be read as “the only place every reserve dollar is held.” Cash outside the fund can sit in FBO accounts at other banks.
Cash banks: distributed FBO accounts
Circle’s 2025 Form 10-K described 10–20% of reserves as typically held in cash in FBO accounts, primarily at GSIBs, with a small fraction at additional banks. The filing does not make that range a fixed daily target. Bank balances, settlement needs, redemptions and fund subscriptions can change the mix.
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Independent accountant: assurance over a defined assertion
A Big Four accounting firm performs monthly third-party assurance. The examination tests management’s reserve assertion against specified criteria. It is not the same as a full financial-statement audit of every Circle entity, and it is not a promise that the reserve composition will remain unchanged after the report date.
Which assets qualify as USDC reserves?
Circle’s reserve standard limits qualifying reserves to the following categories:
- U.S. Treasury securities with three months or less remaining maturity.
- Cash deposits at global banks.
- Overnight tri-party reverse repos fully collateralized by U.S. Treasuries.
- Government money-market funds.
- Products whose underlying assets are limited to those categories.
This list helps you interpret the fund disclosure. A government money-market fund can hold qualifying short-term government assets while still being a fund investment rather than a direct bank deposit. Reverse repos are secured transactions, so the collateral and maturity conditions matter. A reserve report’s fair-value number is therefore not simply a count of dollars sitting in one checking account.
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How to interpret the June 2025 examination figures
The examination’s two central figures answer a specific solvency question for a specific date:
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| USDC in circulation | 61,332,530,506 USDC | The token liability measured at June 30, 2025. |
| Fair value of assets held in USDC Reserve | $61,397,784,739 | The fair value of assets evaluated under the report’s reserve criteria on the same date. |
| Reported excess | $65,254,233 | The arithmetic difference between the two reported amounts; it is not a guarantee against future price, liquidity or legal risk. |
The accountant’s opinion said: “In our opinion, management’s assertion that the Fair Value of Assets Held in USDC Reserve is equal to or greater than USDC In Circulation as of the Report Dates in accordance with the criteria defined in the accompanying USDC Reserve Report is fairly stated, in all material respects.”
That wording matters. “Fairly stated, in all material respects” is an examination conclusion under defined criteria. It does not say that every reserve asset is risk-free, that redemption is instantaneous in every circumstance, or that the figures apply indefinitely after June 30, 2025.
Independent reader supportYour contribution helps us test, update, and keep practical guides available for everyone.Choosing the right verification source
Use the source that matches the question you are asking rather than treating one document as complete proof of everything.
| If you want to know… | Best source | Why | Main limitation |
|---|---|---|---|
| What Circle says about current supply and reserves | Transparency & Stability page | It is updated more often and links to circulation, holdings, flows and assurance reports. | Issuer-controlled overview; always capture the “as of” date. |
| Who manages the fund and where fund assets are held | Latest SEC filing | Regulatory filing explains the Circle Reserve Fund, BlackRock’s role and BNY custody. | Annual or periodic reporting is less timely than daily fund data. |
| What is currently inside the fund | BlackRock USDXX disclosure | The filing says the disclosure is updated daily. | Fund-level scope; it excludes cash held outside the fund. |
| Whether reserves met circulation on a tested date | Independent examination | An outside accountant tests management’s assertion against stated criteria. | It is date-specific and not a full audit of all corporate activity. |
| How reserves are legally described | SEC filing and reserve standard | These describe FBO accounts, permitted assets and encumbrance statements. | Legal treatment in an issuer bankruptcy remains unsettled. |
Important limits: custody is not the same as zero risk
Circle’s SEC filing says reserves are held in accounts titled for the benefit of USDC holders and are not lent, borrowed against or encumbered. That supports operational due diligence: the disclosed structure is designed to keep reserve assets separate from ordinary corporate financing.
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When you assess a stablecoin, separate these questions:
- Asset sufficiency: Did the examined reserve assets meet or exceed tokens in circulation on the report date?
- Asset quality: Were the assets limited to the permitted categories and valued appropriately?
- Operational access: Can eligible customers actually redeem through Circle’s process when markets or banks are stressed?
- Legal segregation: Would holders receive the intended benefit of FBO and custody arrangements in an insolvency?
- Counterparty concentration: Which fund manager, custodian and banks are involved, and how could a failure affect access?
The documents answer the first two questions most directly. They provide useful information for the others but do not make an unconditional promise about a future crisis.
Common mistakes and how to avoid them
Mistake: calling BlackRock the issuer
BlackRock manages the Circle Reserve Fund. Circle Internet Financial, LLC issues USDC. Write those as separate fields in your notes.
Mistake: saying BNY holds every reserve dollar
BNY is custodian for assets in the Circle Reserve Fund and was announced as a primary custodian. Cash held in FBO accounts can be distributed among GSIBs and additional banks.
Mistake: treating 88% as a permanent allocation
The approximately 88% figure belongs to Circle’s December 31, 2025 reporting position. It is not automatically the percentage for October 2026 or any later date.
Mistake: adding the 10–20% cash range mechanically
The filing describes approximately 88% in the fund and says 10–20% was typically cash. Those are approximate descriptions tied to reporting and operating conditions, so rounding and timing can prevent them from totaling exactly 100%.
Mistake: calling an examination a complete audit
The independent report examines a defined reserve assertion. It does not audit every Circle balance sheet, every exchange’s customer account or every future redemption.
Mistake: comparing documents with different dates
Always place the circulation amount, reserve fair value, fund allocation and custody statement beside their respective “as of” dates. A newer daily fund disclosure can coexist with an older annual percentage without either document being wrong.
A practical verification checklist
- Circle’s Transparency & Stability page opened and its dated “as of” line recorded.
- USDC’s legal issuer recorded as Circle Internet Financial, LLC.
- Latest SEC filing identified by filing date and reporting period.
- Circle Reserve Fund identified as a Rule 2a-7 government money-market fund.
- BlackRock recorded as investment manager.
- BNY recorded as custodian for assets in the fund, not as the holder of every reserve asset.
- FBO cash arrangement and the 10–20% typical range recorded with the 2025 Form 10-K date.
- BlackRock USDXX daily disclosure checked for the fund-level portfolio.
- Latest independent examination saved with its report date.
- Circulation and fair-value figures copied exactly and compared only when their dates match.
- Reserve categories, FBO language and bankruptcy-treatment caveat noted.
What a well-documented conclusion looks like
A careful conclusion would read as follows: Circle Internet Financial, LLC is the issuer of USDC. For the position reported at December 31, 2025, Circle said approximately 88% of reserves were in the Circle Reserve Fund, managed by BlackRock, with the fund’s assets held in BNY custody; the remainder was typically cash in FBO accounts, mainly at GSIBs. Circle’s June 30, 2025 independent examination reported 61,332,530,506 USDC in circulation against $61,397,784,739 of fair-value reserve assets and found management’s assertion fairly stated in all material respects. Those statements are dated disclosures, not a guarantee that the same allocation or legal outcome applies indefinitely.
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