Circle Secures NYDFS Charter for USDC Amid GENIUS Act Regulatory Hurdles

Circle has obtained a limited-purpose trust charter from the New York Department of Financial Services (NYDFS) for Circle New York Trust, allowing it to issue its stablecoin USDC. This move follows the company's recent acquisition of IBM's blockchain patent portfolio and strengthens its regulated digital asset strategy.

The GENIUS Act caps state-qualified issuers at $10 billion in outstanding stablecoins before federal oversight applies, but USDC's circulating supply is around $72 billion, making this charter a significant development. Circle has split custody and issuance functions into two separate entities: Circle National Trust, chartered by the OCC for digital asset custody only, and Circle New York Trust, which will handle USDC issuance.

The OCC granted conditional approval to Circle National Trust in December 2025, stating that it would not issue stablecoins. However, the charter has been finalized, and Circle New York Trust has received its NYDFS charter. The company's decision to operate under two separate regulatory frameworks raises questions about how it plans to reconcile the $10 billion cap with USDC's actual size.