NYDFS Grants Circle Limited Purpose Trust Charter for Digital Asset Custody
Key Takeaways
- •NYDFS granted Circle a limited purpose trust charter enabling the company to provide fiduciary, custody, and asset management services under New York Banking Law.
- •Circle now holds separate trust approvals from both NYDFS and the OCC, positioning it among a small group of digital asset firms regulated at both state and federal levels.
- •Circle was the first company to receive a BitLicense from NYDFS in 2015, and the new charter continues that longstanding regulatory relationship.
- •USDC remains the second-largest stablecoin by market capitalization, with a market value exceeding $71.8 billion and Circle's stock trading around $64.24 following the announcement.
- •NYDFS recently proposed updated reserve requirements to align state rules with the federal GENIUS Act, the first comprehensive federal framework for payment stablecoins enacted in 2025.

The New York Department of Financial Services (NYDFS) has granted Circle a limited purpose trust charter, enabling the company to expand its regulated custody and fiduciary services in the state. Circle now holds separate trust approvals from both the NYDFS and the Office of the Comptroller of the Currency (OCC).
Circle announced on Friday that NYDFS had granted a limited purpose trust charter to Circle New York Trust. According to the company, the approval authorizes Circle Internet Trust Company LLC to operate under New York Banking Law while broadening its regulated custody and fiduciary capabilities. CEO Jeremy Allaire said the charter reflects more than a decade of engagement with the state regulator. The dual trust approvals position Circle among a small group of digital asset firms operating under both state and federal banking regulators, a structure that institutional clients increasingly seek for asset segregation and regulatory assurance.
Strengthened Regulatory Framework
According to Circle, the limited purpose trust charter reinforces the regulatory framework supporting USDC and the company's operations in New York. The company noted that its global headquarters are located in New York and described the approval as a longstanding objective.
Allaire said the charter provides additional regulatory clarity for Circle's business and characterized NYDFS as an international standard for digital asset regulation.
Circle became the first company to receive a BitLicense from NYDFS in 2015. The company said the latest approval continues that regulatory relationship.
Expanded Trust Services
The trust charter allows Circle New York Trust to provide fiduciary, custody, and asset management services under New York Banking Law. Unlike traditional commercial banks, trust companies do not accept consumer deposits or issue loans.
Early last month, Circle also received approval from the OCC to establish Circle National Trust. According to Circle, the national trust bank will provide digital asset custody and fiduciary services while enhancing oversight of USDC reserves.
The company said the OCC approval and the New York trust charter represent separate regulatory authorizations, with both expanding Circle's regulated trust operations across the United States. The approvals come as competition intensifies in the regulated stablecoin sector, with Tether's USDT remaining the largest stablecoin by market capitalization and traditional financial institutions exploring tokenized payment products.
USDC Under Continued Oversight
USDC remains the second-largest stablecoin by market capitalization. Circle's stock traded around $64.24 following Friday's announcement, while USDC's market value exceeded $71.8 billion. Circle began trading publicly on the New York Stock Exchange in June 2025.
Circle joins several digital asset companies that have previously secured limited purpose trust charters from NYDFS, including Coinbase, MoonPay, BitGo, and Paxos.
NYDFS recently proposed updated reserve requirements as it aligns state rules with the federal GENIUS Act, the first comprehensive federal framework for payment stablecoins enacted in 2025. Acting Superintendent Kaitlin Asrow previously stated that New York's framework has supported stable digital asset markets while protecting consumers.