https://www.esma.europa.eu/taxonomy/2025-03-31/mica/#AutoritedeControlePrudentieletdeResolutionACPR https://www.esma.europa.eu/taxonomy/2025-03-31/mica/#DevelopmentTeam https://xbrl.org/2024/iso3166#FR https://www.esma.europa.eu/taxonomy/2025-03-31/mica/#DevelopmentTeam https://xbrl.org/2024/iso3166#US https://www.esma.europa.eu/taxonomy/2025-03-31/mica/#EmoneyTokenWhitePaper https://www.esma.europa.eu/taxonomy/2025-03-31/mica/#ModifyTypeOfSubmission https://www.esma.europa.eu/taxonomy/2025-03-31/mica/#FranceMemberState https://www.esma.europa.eu/taxonomy/2025-03-31/mica/#AustriaMemberState https://www.esma.europa.eu/taxonomy/2025-03-31/mica/#BelgiumMemberState https://www.esma.europa.eu/taxonomy/2025-03-31/mica/#BulgariaMemberState https://www.esma.europa.eu/taxonomy/2025-03-31/mica/#CroatiaMemberState https://www.esma.europa.eu/taxonomy/2025-03-31/mica/#CyprusMemberState https://www.esma.europa.eu/taxonomy/2025-03-31/mica/#CzechiaMemberState https://www.esma.europa.eu/taxonomy/2025-03-31/mica/#DenmarkMemberState https://www.esma.europa.eu/taxonomy/2025-03-31/mica/#EstoniaMemberState https://www.esma.europa.eu/taxonomy/2025-03-31/mica/#FinlandMemberState https://www.esma.europa.eu/taxonomy/2025-03-31/mica/#FranceMemberState https://www.esma.europa.eu/taxonomy/2025-03-31/mica/#GermanyMemberState https://www.esma.europa.eu/taxonomy/2025-03-31/mica/#GreeceMemberState https://www.esma.europa.eu/taxonomy/2025-03-31/mica/#HungaryMemberState https://www.esma.europa.eu/taxonomy/2025-03-31/mica/#IcelandMemberState https://www.esma.europa.eu/taxonomy/2025-03-31/mica/#IrelandMemberState https://www.esma.europa.eu/taxonomy/2025-03-31/mica/#ItalyMemberState https://www.esma.europa.eu/taxonomy/2025-03-31/mica/#LatviaMemberState https://www.esma.europa.eu/taxonomy/2025-03-31/mica/#LiechtensteinMemberState https://www.esma.europa.eu/taxonomy/2025-03-31/mica/#LithuaniaMemberState https://www.esma.europa.eu/taxonomy/2025-03-31/mica/#LuxembourgMemberState https://www.esma.europa.eu/taxonomy/2025-03-31/mica/#MaltaMemberState https://www.esma.europa.eu/taxonomy/2025-03-31/mica/#NetherlandsMemberState https://www.esma.europa.eu/taxonomy/2025-03-31/mica/#NorwayMemberState https://www.esma.europa.eu/taxonomy/2025-03-31/mica/#PolandMemberState https://www.esma.europa.eu/taxonomy/2025-03-31/mica/#PortugalMemberState https://www.esma.europa.eu/taxonomy/2025-03-31/mica/#RomaniaMemberState https://www.esma.europa.eu/taxonomy/2025-03-31/mica/#SlovakiaMemberState https://www.esma.europa.eu/taxonomy/2025-03-31/mica/#SloveniaMemberState https://www.esma.europa.eu/taxonomy/2025-03-31/mica/#SpainMemberState https://www.esma.europa.eu/taxonomy/2025-03-31/mica/#SwedenMemberState https://www.esma.europa.eu/taxonomy/2025-03-31/mica/#OfferToPublic 969500OYUDADGZKCR583 2025-01-01 2025-12-31 969500OYUDADGZKCR583 2025-12-31 969500OYUDADGZKCR583 2025-01-01 2025-12-31 1 969500OYUDADGZKCR583 2025-01-01 2025-12-31 2 969500OYUDADGZKCR583 2025-01-01 2025-12-31 1 969500OYUDADGZKCR583 2025-01-01 2025-12-31 2 969500OYUDADGZKCR583 2024-10-17 2025-10-16 969500OYUDADGZKCR583 2024-10-17 969500OYUDADGZKCR583 2025-10-16 xbrli:pure utr:kWh utr:tCO2e
1
Circle Internet Financial Europe SAS
USDC
White Paper
(Articles 51 to 53 of MiCA regulation)
This white paper was notified to the Autorité de contrôle prudentiel et de résolution on May 31st, 2024, and amended on September 12
th
, 2024
and December 16
th
, 2025.
N
FIELD
CONTENTS
I.00
Table of contents
I.01 – Date of notification
I.02 – Statement in accordance with Article 51(3) of Regul ation (EU) 2023/1114
I.03 – Compliance statement in accor dance with Article 51(5) of Regulation (EU) 20 23/1114
I.04 – Warning in acc ordance wit h Article 5 1(4), point s (a) and (b) of Regula tion (EU) 20 23/1114
SUMMARY
I.05 – Warning in acc ordance wit h Article 5 1(6), second subparagra ph of Regula tion (EU) 20 23/1114
I.06 – Characteristics of the cry pto-asset
I.07 – Right of redemption
I.08 – Key information about the of fer and/ or admission t o trading
PART A - INFORMATION ABOUT THE ISS UER OF THE E-MONEY TOKEN
A.1 – Statutory name
A.2 - Trading name
A.3 – Legal form
A.4 – Registered address
A.5 – Head office
A.6 – Registration date
A.7 – Legal entity identifier
A.8 – Another identifier re quired pursuant to app licable law
A.9 – Contact telephone number
A.10 – E-mail address
A.11 – Response time (days)
A.12 – Parent company
A.13 – Members of the manag ement body
A.14 – Business activity
A.15 – Parent company business a ctivity
A.16 – Conflicts of interest disclosure
A.17 – Issuance of other crypto-assets
A.18 – Activities related t o other crypto-assets
A.19 – Connection between the i ssuer and the entity running the DLT
A.20 – Description of the con nection between the is suer and the entity ru nning the DLT
A.21 – Newly established
A.22 – Financial condition over the past three ye ars
A.23 – Financial condition since registration
A.24 – Exemption from authorisati on
A.25 – E-money Token authorisat ion
A.26 – Authorisation authori ty
A.27 – Persons other than the i ssuer offering to the public or seeking a dmission to trading of the e-
money token in acco rdance with Arti cle 51(1), secon d subparagraph of Regulation (EU) 2023/1114
A.28 – Persons other than the i ssuer offering to the public or seeking a dmission to trading of the e-
money token in acco rdance with Arti cle 51(1), secon d subparagraph of Regulation (EU) 2023/1114
A.29 - Reason for offering to the public or seeki ng admission to tradin g of the e-money token by
persons referred to in Article 51(1), second subparagraph of Regulation (EU) 2023/1114
PART B - INFORMATION ABOUT THE E-MONEY TOKEN
B.1 – Name
B.2 – Abbreviation
B.3 – Details of all natur al or legal persons involved in design and development
A DESCRIPTION OF THE CHARACTERISTICS OF THE E-MONEY TOKEN, INCLUDING THE DATA
NECESSARY FOR CLASSIFICATION OF THE CRYPTO-ASSET WHITE PAPER IN THE REGISTER
REFERRED TO IN ARTICLE 109, AS SPECIFIED IN ACCORDANCE WITH PARAGRAPH 8 OF THAT
ARTICLE
B.4 – Type of white paper
B.5 – The type of submission
B.6 – Crypto-assets characteristics
B.7 – Website of t he issuer
B.8 – Starting date of offer to the public or admis sion to trading
B.9 – Publication d ate
B.10 – Any other services prov ided by the i ssuer
B.1 1 – Language or languages of the white paper
B.1 2 – Digital t oken i dentifier c ode used to uniquely identify the crypt o-asset or each of the several crypto
assets to which the white paper relates, where available
B.1 3 – Functionally f ungible g roup d igital Token Identifier, where available
B.14 – Personal data flag
B.1 5 – LEI eligibility
B.1 6 – Home member state
B.1 7 – Host member states
PART C - INFORMATION ABOUT THE O FFER TO THE PUBLIC OF THE E-MONEY TOKEN OR ITS
ADMISSION TO TRADING
C.1 – Public offering or tr ading
C.2 – Number of units
C.3 – Trading platforms
C.4 – Trading p latforms Market Identifier C ode (MIC)
C.5 – Applicable law
C.6 – Competent court
PART D - INFORMATION ON THE RIGHT S AND OBLIGATIONS ATTACHE D TO E-MONEY TOKENS
D.1 – Holder’s rights and o bligations
D.2 – Conditions of modifica tions of rights and o bligations
D.3 – Description of the ri ghts of the holders
D.4 – Rights in implementatio n of recovery plan
D.5 – Rights in implementatio n of redemption plan
D.6 – Complaint submission con tact
D.7 – Complaints handling pr ocedures
D.8 – Dispute resolution mech anism
D.9 – Token value protection schemes
D.10 – Token v alue p rotection s chemes d escription
D.11 – Compensation s chemes
D.12 – Compensation s chemes d escription
D.13 – Applicable law
D.14 – Competent court
PART E - INFORMATION ON THE UNDER LYING TECHNOLOGY
E.1 – Distributed ledger te chnology
E.2 – Protocols and technica l standards
E.3 – Technology used
E.4 – Purchaser’s technical requirements
E.5 – Consensus mechanism
E.6 – Incentive mechanisms and applicable fe es
E.7 – Use of distributed le dger technology
E.8 – DLT functionality desc ription
E.9 – Audit
E.10 – Audit outcome
PART F - INFORMATION ON THE RISKS
F.1 – Issuer-related risks
F.2 – Token-related risks
F.3 – Technology-related risks
F.4 – Mitigation measure s
PART G - INFORMATION ON THE SUSTA INABILITY INDICATORS IN RELATIO N TO ADVERSE IMPACT
ON THE CLIMATE AND OT HER ENVIRONMENT-RELATED ADVERSE IMPACTS
G.1 – Adverse impacts on cli mate and other environmen t-related adverse impacts
I.01
Date of notification
2025-12-29
I.02
Statement in
accordance with
Article 51(3) of
Regulation (EU)
2023/1114
This crypto asset white paper has not been app roved by any competent au thority in any Member Stat e of the
European Union. The issu er of the crypto-asset is solely responsible for the content of this White Paper.
I.03
S tatement in
accordance with
Article 51(5) of
Regulation (EU)
2023/1114
This crypto-asset white paper complies with Title IV of Regulati on (EU) 2023/1114 of the European Parliament
and of the Council and to the best of the knowledge of the management body, the information presented in the
crypto-asset white paper is fair, clear, and not misleading and the crypto-asset white paper makes no
omission likely to affect its import.
I.04
Warning in
accordance with
Article 51(4),
points
(a) and (b) of
Regulation (EU)
2023/1114
The e-money token is not covered by the investor compensat ion schemes under Direct ive 97/9/EC of the
European Parliament and o f the Council or the d eposit guarantee schemes under Directive 2014/49/EU of the
European Parliament and o f the Council.
SUMMARY
I.05
Warning in
accordance with
Article 51(6),
second
subparagraph of
Regulation (EU)
2023/1114
Warning
This summary should be rea d as an introduction to the crypto-asset white paper. The prospective holder
should base any decision to purchase this e-money token o n the content of the crypto-asset white paper as a
whole and not on this summary alone.
The offer to the publi c of this crypto asset does not constitute a n offer or solicitat ion to purchase finan cial
instruments and any suc h offer or solicitation can be made only by means of a prospectus or oth er offer
documents pursuant to the applicable nat ional law.
This crypto-asset white paper does not constitute a pr ospectus as referred to in Regulation (EU) 2017/1129 of
the European Parliament and of the Cou ncil or any other offer document pursuan t to European Union or
national law.
I.06
Characteristics
of the crypto-
USDC is an e-money token ("EMT"), available on public blockchain networks. USDC p rovides a faster, safer,
and more efficient way to send, spend, and exchange money around the world.
asset
For every USDC issued by Ci rcle SAS and remaining i n circulation in th e European Economic Area ("EEA"),
Circle SAS will hold e ither one U.S. Dollar ("USD") or an equivalent amount of USD-denominated assets on
behalf of holders, in order to facilitate the frictionless movement of the e-money tokens, utilizing block chain
technology. As a fully reserved e-money token, USDC is backed b y an equivalent a mount of U.S. Dollar-
denominated assets held by Circle SAS and redeemable 1:1 for U.S. dollars.
I.07
Right of
redemption
The holders of this e-money token have a righ t of redemption at any time and a t par value. Thi s applies to
holders of USDC resident in the EEA. Conditions and processes for redemption of USDC are detailed in our
Redemption Policy avail able on Circle’s website (the "Websit e").
For holders of USDC locate d outside the EEA, pleas e refer to the specifi c USDC Terms of Circle Internet
Financial, LLC, organi sed under the laws of the state of Delaware, USA, with a registered off ice at 1 Lincoln,
Ste 31-113 Boston, MA, 02111 ("Circle LLC").
I.08
Key information
about the offer
and/ or
admission to
trading
USDC is only available for issuance through the Circle Mint service and it is accessible only to institutions
located in supported jurisd ictions. For a complete list of currently supporte d jurisdictions, please cons ult our
Website. USDC is listed across different regulated crypto-asset service providers and Circle SAS intends to
seek its admission to trading on future MiCA-compliant trading platforms.
PART A - INFORMATION ABOUT THE ISSUER OF THE E-MONEY TOKEN
A.1
Statutory name
Circle Internet Financ ial Europe SAS (“Circle SAS”)
A.2
Trading name
Circle France
A.3
Legal form
Not applicable as LEI is provided in A.7
A.4
Registered
address
Not applicable as LEI is provided in A.7
A.5
Head office
Not applicable as LEI is provided in A.7
A.6
Registration date
2023-07-10
A.7
Legal entity
identifier
969500OYUDADGZKCR583
A.8
Another
identifier
required
pursuant to
applicable law
Not applicable as LEI is provided in A.7
A.9
Contact
telephone
number
+33 (1) 59000130
A.10
E-mail address
EEA-Customer-Support@circle.com
A.11
Response time
(days)
007
A.12
Parent company
Not applicable as LEI is provided in A.7
A.13
Members of the
management body
Identity
Business Address
Function
Mrs. Coralie
Billmann
4 RUE DE MARIVAUX, 75002
PARIS – France
Président (President)
Mr. Michel Vaugiac
4 RUE DE MARIVAUX, 75002
PARIS - FRANCE
Directeur Général
(General Manager)
A.14
Business activity
Circle SAS is a Digital Asset Services Provide r registered with the AMF under number E2024-111, authorised
to provide digital assets custody and trading o f digital assets against other digital assets since 15 A pril 2024.
Circle SAS is also an El ectronic Money Institu tion registered with the ACPR under number 17788, and
provides e-money token services.
A.15
Parent company
business activity
Circle Internet Group, I nc. is the holding c ompany for the Circle gr oup. Its shares have be en listed on the New
York Stock Exchange since June 5, 2025.
A.16
Conflicts of
interest disclosure
We frequentl y engage wit h a wide va riety of bl ockchain an d digital asset indus try partici pants, as w ell as
startups and growth companies, and maintain relationships with a si gnificant number of crypto-asset projects,
developers, and investors. These transa ctions and relationships could create potential conflicts of interest in
management decisions that we make. For instance, cert ain of our offi cers, directors, and employees ar e active
investors in crypto-asset projects and other growth companies themselves, and may make investment
decisions that favor projects in which they have personally invested. Many of our large shareholders also make
investments in these pro jects.
A.17
Issuance
of other
crypto-
assets
True
A.18
Activities related
to other crypto-
True
assets
A.19
Connection
between the
issuer and the
entity running the
DLT
True
A.20
Description of the
connection
between the
issuer and the
entity running the
DLT
USDC is issued on 31 dif ferent blockchain net works (see items E.2 and E.3). The list of USDC Suppor ted
Blockchains may be amended from time to time and upda ted on the following Website
For most of these blockch ains, Circle has ente red into agreements with the blockchain enti ty or foundation,
where it exists, responsible for its adoption, by which Circle agrees to design and deploy US DC on blockchain
networks, to make it available on the Circle Mi nt application, and to offer support to Cir cle clients accordi ngly.
Circle, for regulator y reasons (including transaction monitorin g), and as part of its commitment to support the
ecosystem, runs a node on each of the supported blockchains.
It is common practice for the relevant blockc hain foundation to support Circle's technical dev elopment efforts
through a one-off financial compensatory payment.
A.21
Newly established
True
A.22
Financial
condition for the
past three years
Not applicable
A.23
Financial condition
since registration
Circle SAS was created on June 30, 2023.
Between June 30, 2023, an d July 1, 2024, Circl e SAS did not engage in any commercial activiti es. The
company was formally incorporated on July 10th, 2023, but its oper ational activities, including the issuance of
EURC and USDC, commenced on July 1, 2024, a fter the completion of the necessary regulatory approvals.
Circle SAS started its a ctivities of issuan ce of EURC and USDC on July 1, 2024. The share capita l of Circle
SAS as of September 30th, 202 5 corresponds to €159,0 00,000.00. In FY2024, Cir cle SAS reported a turnov er
(Net Banking Income) equal to €3,300,1 19. As of December 31, 2024, Circle SAS reported corporate cash of
€17,871,528 and net assets of €26,309,821.
A.24
Exemption from
authorisation
False
A.25
E-money token
authorisation
Circle SAS is a licens ed Electronic Money Inst itution under n°73715 8 and a registered Dig ital Assets Services
Provider in France unde r n°E2024-111.
A.26
Authorisation
authority
French Autorité de Contrôle Prudentiel et de Résolution (ACPR)
A.27
Persons other
than the issuer
offering to the
public or
seeking
admission to
trading of the e-
money token in
accordance with
Article 51(1),
second
subparagraph,
of Regulation
(EU) 2023/1114
Not applicable.
A.28
Persons other
than the issuer
Not applicable.
offering to the
public or
seeking
admission to
trading of the e-
money token in
accordance with
Article 51(1),
second
subparagraph,
of Regulation
(EU) 2023/1114
A.29
Reason for
offering to the
public or seeking
admission to
trading of the e-
money token by
persons referred
to in Article 51(1),
second
subparagraph, of
Regulation (EU)
2023/1114
Not applicable.
PART B - INFORMATION ABOUT THE E-MONEY TOKEN
B.1
Name
Not applicable as a DTI is provided in fie ld B.12
B.2
Abbreviation
Not applicable as a DTI is provided in fie ld B.12
B.3
Details of all
natural or legal
persons involved
in design and
development
Identity
Business Address
Circle SAS
4 Rue de Marivaux, 75002 Paris, FRANCE
Circle Internet Financ ial LLC
1 Lincoln, Ste 31-113
Boston, MA, 02111, USA
A DESCRIPTION OF THE CHARACTERISTICS OF THE E-MONEY TOKEN, INCLUDING THE DATA NECESSARY FOR
CLASSIFICATION OF THE CRYPTO-ASSET WHITE PAPER IN THE REGISTER REFERRED TO IN ARTICLE 109, AS SPECIFIED IN
ACCORDANCE WITH PARAGRAPH 8 OF THAT ARTICLE
B.4
Type of white
paper
EMTW
B.5
The type of
submission
MODI
B.6
Crypto-asset
characteristics
USDC is defined as an e-money t oken pursuant to Article 3.1(7) of MiCA.
As of the date of this White Paper, USDC does not co nstitute a “signifi cant e-money token” as defined
by Article 56 of MiCA.
USDC is a digital token pegged to the USD and was first issued by Circl e LLC in September 2018. From July
1st, 2024, Circle SAS became a second, or "dual”, issuer of USDC.
USDC issued by Circle SAS ar e fully fungible wi th those issued by Cir cle LLC. USDC is fully b acked by an
equivalent amount of USD-denominated assets held. There are reserves with Circle SAS for EEA holders and
with Circle LLC for Non-EEA hol ders. These reserves are held with regulated financial institut ions in
segregated accounts separate from Circle SAS’s corporate funds, on behalf of, and for the benefit of, holders
of USDC in the EEA (the "Segregated Accounts"). This means that for every USDC issued by Circle SAS or
by Circle LLC and remaining in circulation, Circle SAS or Circle LLC holds on behalf of holders either one USD
or an equivalent amount of USD-denominated assets in their Segregated Accounts (the "USDC Re serves").
The USDC Reserves are indepe ndently reviewed by a leading accounting f irm, providing monthly confirmation
that they match or exceed the USDC in circulation. USDC is not designed to create return s for holders,
increase in value, or othe rwise accrue financial be nefit to the USDC ho lder.
B.7
Website of the
issuer
Circle website (the "Websi te")
B.8
Starting date of
offer to the
public or
admission to
trading
2024-07-01
B.9
Publication date
2026-01-28
B.10
Any other services
provided by the
issuer
Circle SAS is a registe red Digital Assets Serv ices Provider in Franc e under n°E2024-111. It provides Digital
assets custody and trading of digital assets against other digital assets.
B.11
Language or
languages of the
white paper
English
B.12
Digital token
identifier code
used to uniquely
identify the
crypto-asset or
each of the
Blockchain
DTI Code
Algorand
M8G59S1ZR
several crypto
assets to which
the white paper
relates, where
available
Aptos
6BGZTT6GF
Arbitrum
4ZSZS1F4F
Avalanche
45J6XJX7H
Base
CP6817N4B
Celo
2ZTG3NNVB
Codex
VXJX1WW6V
Ethereum
CK9PW1MFH
Flow (deprecated)
P7H2X1B9H
Hedera
XTS66R22W
HyperEVM (Hyperliquid)
GN9M0Z238
Ink
R3SV04GX9
Linea
RWPZZPR7C
Monad
S28NDWCSX
NEAR
W2PQJJCPM
Noble
7NZRGQZ87
Optimism
898NNTPZJ
Plume
N064ZKXDM
Polkadot Asset Hub
J2TPM5RFQ
Polygon PoS
LS71LQK3L
Ripple (XRPL)
RN81GQLBH
Solana
5R3XFPZSM
Sonic
MKC04VFBQ
Stellar
DWBBXD2F1
Sei
TSLS4S9R8
Sui
FXZLG37L6
Tron (deprecated)
T6TQ8GN7L
Unichain
56V43DKZ3
World Chain
QQKDMF6N9
XDC
SKXZGD4J8
ZKsync Era
54VFN74B3
B.13
Functionally
fungible group
digital token
identifier, where
available
TJWK5QTRK
B.14
Personal data flag
True
B.15
LEI eligibility
True
B.16
Home Member
State
France
B.17
Host Member
States
Circle SAS license to issue, distribute and redeem electronic money is passported in the following countries:
Austria
Belgium
Bulgaria
Cyprus
Czech
Germany
Denmark
Estonia
Spain
Finland
Greece
Croatia
Hungary
Ireland
Iceland
Italy
Liechtenstein
Lithuania
Luxembourg
Latvia
Malta
Netherlands
Norway
Poland
Portugal
Romania
Sweden
Slovenia
Slovakia
PART C - INFORMATION ABOUT THE OFFER TO THE PUBLIC OF THE E-MONEY TOKEN OR ITS ADMISSION TO TRADING
C.1
Public offering
or trading
OTPC
C.2
Number of units
77085392385
C.3
Trading platforms
name
USDC is listed on major g lobal regulated cryp to-asset trading platforms operating in the EEA, including for
example Bitstamp, Bitvavo, Kraken, ZBX and OKX. Circle SAS intends to maintain these listings as long as
doing so remains compliant with Applicable Laws.
C.4
Trading
platforms
market identifier
code (MIC)
USDC is listed on numerous trading platforms, including (for those having an MIC):
Bitstamp: BESA
Bitvavo: VAVO
ZBX: ZBXE
Kraken: PESL
C.5
Applicable law
France
C.6
Competent court
Any dispute with the of fer to the public of USDC in the EEA shall be br ought exclusively i n the Commercial
courts of Paris, France except where prohibited by the laws of France (the "Applicable Laws").
PART D - INFORMATION ON THE RIGHTS AND OBLIGATIONS ATTACHED TO E-MONEY TOKENS
D.1
Holder’s rights
and
obligations
USDC issued by Circle SAS i s an EMT subject to MiCA regu lation and Applicabl e Laws. Under these
regulations, EMT means a type of cryp to-asset that purports to maintain a stable val ue by referencing the value
of one official currency.
Holding USDC tokens does n ot provide rights to USDC holders other than th ose rights provided wi thin this
White Paper, as well as under MiCA r egulation a nd Applicab le Laws. Persons h olding USDC, located out side
the European Economic Area (EEA), s hall refer to the Circle Mint User Agreement and/or the app licable USDC
Terms issued by Circle L LC, particularly with respect to the redempti on of USDC, and shall not have any right
to seek redemption from Circle SAS. For pu rposes of this White Paper, the term “USDC Holders” shall refer
exclusively to holders of USDC located within the EEA.
USDC Holders understand tha t sending USDC to another address automatically transfers and assigns to the
owner of that address, and any subsequent USDC holder, the right to r edeem USDC for USD funds so long as
the USDC Holder is eligible to.
USDC transactions are not reversible. Once USDC Holde rs send USDC to an address, USDC Holders accept
the risk that they may lose access to, an d any claim on, that USDC indefinitely or perman ently. For example, (i)
an address may have been entered incorrect ly and the true owner of the addr ess may never be discov ered, (ii)
USDC Holders may not have (or subsequently lose) t he private key associ ated with such address, (iii) an
address may belong to an entity that will not return the USDC, or (iv) an address belongs to an entity that may
return the USDC but first requires action on their pa rt, such as verification of USDC Holders’ identity. For the
avoidance of doubt, Circle SAS does not have to track, verify or determine the provenance of USDC balances
for USDC Holders outside of Circle Mi nt, including any fo rm of security interest s claimed thereon unle ss
otherwise stated in the Applicable Laws.
USDC Holders have a legal claim against Circle SAS as the EEA issuer of USDC. These holders are enti tled to
request redemption of their USDC from Circle S AS. Such redemption will be made at any tim e and at par
value, subject to complying with AML requireme nts.
USDC Holders shall have t he right to request re demption of their USDC from Ci rcle SAS with respect to any
USDC issued on a blockcha in supported by eithe r Circle SAS or Circle L LC.
While Circl e SAS may hol d the USDC Res erves in in terest-bearing accounts or other yield-generating
instruments, USDC H olders acknowledge that they are not entitled to any interest or other r eturns earned on
such funds. USDC does not itself gene rate any int erest or return for USDC Holders and only repr esents your
right to redeem USDC for an equivalent am ount of USD as provided in the present W hite Paper.
As required by its li cense, Circle SAS will validate and process redemptions for USDC Holder s that
successfully pass prior Anti-Money Launderin g ("AML") checks, which include:
● Collection of releva nt Know Your Customer documents;
● Verification of iden tity and screening ve rsus international s anctions lists;
● Verification of the v alidity of the trans action by which the USDC wa s acquired;
● Verification of bank details; and
● Circle’s Compliance de partment validation.
More information on the redemption of USDC within the EEA is provi ded in the Circl e SAS Redemption P olicy
available on Circle’s Website.
The holding of USDC will not result in: (i) the creation or imposi tion of any lien upo n any property, asset, or
revenue of Circle SAS or (ii) the creation of any sha reholding or ownership interest in Circle SAS, Circle LLC,
or any of their respective affil iates.
By holding, using, or accessing USDC, USDC Holders further represent and wa rrant that:
● they are holding and using USDC in comp liance with this White Paper and Applicable Laws;
● they are at least 18 years old, are not a Res tricted Person (as defined in the Redemption Policy), are
not owned or controlled by a Restricted Person. and are not hol ding USDC on behalf of a Restricted
Person; and
● they will not be using USDC for any illegal activity including, but n ot limited to, illegal gambling, money
laundering, fraud, blackm ail, extortion, ransoming data, terrorism financing, other violent activities, or
any prohibited market practices. For more details, please consult Ci rcle’s Acceptable Use Policy.
USDC Holders accept that Ci rcle SAS reserves the ri ght to block certain USDC addresses that it det ermines, in
its sole discretion, may b e associated with illegal ac tivity or activity that oth erwise violates Circle SA S’s Terms
of Use and/or this White Paper ("Blocked Address(es)"). In certain circumstances, Circle SAS may deem it
necessary to report such suspected illegal activity to relevant law enforcement agencies and USDC Holders
may forfeit any rights associated with their USD C, including the ability to redeem USDC for USD. Circle SAS
may also be requir ed to freeze USD C and/or surrende r associated USD held in segregate d accounts in the
event it receives a legal order from a valid government authority requiring it to do so.
USDC is also issued and redeemed in accordance wi th Circle's Stablecoin Access Den ial Policy. Circle SAS
reserves the right to block the transfer of USD C to and from an address on chain as permitted under such
policy.
USDC Holders shall hold and use USDC exclusively for their own account and shall in no case be considered
as nominees or agents of Circle SAS, unless otherwise expressly agreed in wri ting by Circle SAS.
USDC Holders are duly inf ormed that Circle SAS’s l iability (and its affiliates, its res pective officers, di rectors,
agents, joint venturers, employees, and suppliers) is l imited to what is expressly provided in the Applicable
Laws and the present White Paper. In particular (but without limitation), USDC Holders are duly informed and
acknowledge that Circle SAS shall bear no liability with regard to i) their use of USDC; (ii) claims or issue
concerning the cost of procurement of substitute goods and servi ces resulting from any goods, data,
information, or services purchased or obtained or messages received or transactions entered into involving
USDC; or (iii) unauthori sed access to or alte ration of USDC Holders tra nsmissions or data inc urred by the use
of USDC.
In this respect, to the full extent permissible by App licable Laws, Circle SAS disclaims all warranties, express or
implied, including, but not limited to, implied warran ties of merchantability an d fitness for a particular purpose.
To the full extent per mi ssible by Applicable Laws, Circle SAS shall not be liable for any damages of any kind
arising from the use of USDC, including, but not limited t o direct, indirect, incidental, punitive and consequential
damages.
D.2
Conditions of
modifications of
rights and
obligations
The rights and obliga tions associated with USDC and applicable to EEA holders are availab le in the
Redemption Policy and Ter ms of Use available on Circle’s Website.
Circle SAS reserves the r ight to amend these rig hts and obligations from time to time, and wil l inform its
customers of such changes through amendments of this White Paper or the Redemption Policy on Circle’s
Website, or through any other channel of communication considered v alid, including on Circle’s Website.
As provided by Article 51 of MiCA regulation, any significant new f actor, any material mist ake or any material
inaccuracy that would be capable of affecting the assessment of USDC will be described in a m odified version
of this White Paper and notified to the competent authorities and published on Circle’s Website, except when
these modifications are related to the impleme ntation by Circle SAS of its Recovery Plan or Red emption Plan
(please refer to Sections D.4 and D.5 below).
D.3
Description of
the rights of the
holders
Should it become insol vent, Circle SAS has impl emented high standards f or safe and sound fina ncial
management of its business. In a si tuation of fin ancial duress or in periods of e conomic uncertaint y, Circle SAS
has established contingency plans to prevent any impact on its activit ies, including the issuance of USDC, or
the rights of USDC Holders.
Where Circle SAS is not a ble to ful fill its o bligations or in the event of in solvency, t he USDC Reserv es are duly
protected in compliance with the Applicable Laws. In particular, the funds received in exchange for issuance of
USDC are protected against any recourse by other creditors of Circle SAS, including in the event of
enforcement proceedings or insolvency proceedings against Circle SAS.
If a situation of financial duress or insolvency were to occur, Circle SAS will implement its Recovery and/o r
Redemption Plan to allo w USDC Holders to exercise their redemption right s on USDC as further speci fied in
Sections D.4 and D.5 bel ow.
D.4
Rights in
implementation of
recovery plan
Depending on the speci fic circumstance(s) und er which the Recovery Pl an implemented by Circle SAS in
compliance with Article 55 of MiCA might be triggered, Circle SAS may have to impose one or more specific
restrictions on the redemption of USDC.
USDC Holders will be dul y informed about any suc h restrictions on Cir cle’s Website. Customers will also be
informed via their Circle Mint Account or anothe r valid means of commu nication between Circle S AS and the
Customer. For instance, Ci rcle SAS may temp orarily impose:
● liquidity fees on redemptio ns;
● limits on the amount of USDC that can be re deemed on any working day – such limit will be set both at
aggregate levels (e.g. as a percentage of the entire amount of tokens issued) and at wallet levels;
● suspension of redemptions, as a last resort.
Example actions listed above don’t constitu te an exhaustive lis t; other actions may be taken by Circle SAS in
accordance with its Recovery Plan
These restrictions wil l be implemented durin g periods of market stre ss and Circle SAS will work to restore
normal operating conditions – subject to regulatory requirements – in collaboration with the ACPR.
D.5
Rights in
implementation of
redemption plan
The Redemption Plan implemen ted by Circle SAS in compl iance with Article 5 5 of MiCA is an operatio nal plan
to support the orderly redemption of USDC in circulation.
The Redemption Plan will be triggered upon a d ecision by the ACPR if Ci rcle SAS is unable or likely to be
unable to fulfill its obligations, includi ng in the case of insolvency, resolution, or the wit hdrawal of authorisation
of Circle SAS as an E-Money Ins titution. The processes set forth in the Redemption Plan will be established
with a view to ensurin g the equitable treat ment of all USDC holders a nd the protection of t he right of
redemption attached to USDC as des cribed above.
If the ACPR triggers the implementation of the R edemption Plan, any individual claim under Sec tion D.1 above
will be suspended. Ci rcle SAS will commence the orderly redemption for all USDC Holders in an e quitable
manner.
As part of this process, a notice will be p ublished informing al l USDC Holders about the process and timelines
to submit their redemption claim. Specifically, the notice will describe the main steps of the redemption
process, including the exact date and t ime when the redemption plan has been activated, the minimum
information necessary to file a redemption claim, where the claim should b e filed, and the time fra me within
which USDC Holders are requ ired to file their claim. The notice will also contain impo rtant information
regarding redemption conditions and tech nical support.
Redemption requests submit ted via a redemption cl aim form will be subje ct to certain eligi bility criteria
described in the Redemption Policy, and as further specified i n the Redemption Plan notice information,
including their identity, the ir token holdings, AML/C FT compliance, their b ank account details, and other
information required to f ile their redemption reque st.
D.6
Complaint
submission
contact
If you have a complaint, please first contact C ircle SAS at EEA-Customer-Support@circle.com, or visit the
Circle Support Portal.
D.7
Complaints
handling
procedures
USDC Holders can file a complaint by leaving a message at the contact number provided in Section A.9 or filing
it through the customer support email address. Upon receiving a complaint, the Customer Care Team member
will log the case and escalate it to a Customer Care Manag er. The Cust omer Care Manage r is respo nsible for
reviewing the details of the complaint.
Circle SAS handles co mplaints submitted by its direct Customers or by USDC Holders exp eriencing issues wi th
the USDC redemption process for their USDC. However, complaints relating to the purchase of USDC from third
parties or to the loss of tokens held in self-custody or custodied with third part ies fall outside the scope of Circle
SAS's Customer Care support.
If appropriate, all details and data will be compiled and es calated to the Legal Department. When such an
escalation occurs, the Legal Department is responsi ble for investigating the case and working towards closure.
If escalated to the Legal Department, all communications with the customer will be instructed by the Legal
Department.
The Cust omer Care Depart ment wil l re main ac tively involved in any customer complaint or service requirement
and serves as a first line of support and an advocate f or customers prior to any internal escalation.
1st level
2nd level escalations
3rd level escalations
Customer Complaints
Customer Care
Customer Care
Manager
Legal Department
Complaints For Fraud
Customer Care
Customer Care
Manager
Legal Department
Technical Issues
Customer Care
Engineer / Technical
Operations
Engineer Manager
Claim Management
Customer Care
Customer Care
Manager
Legal Department
D.8
Dispute resolution
mechanism
In the event that Circle SAS’s response to the ir complaint is not satisfactory, USDC Holders and customers can
refer their claim to the ACPR:
● By mail sent to the fol lowing address:
Banque de France - ACPR
TSA 50120
75035 PARIS CEDEX 01
● By electronic means, by c reating an account on the online applicat ion portal of the Banq ue de France
(https://accueil.banque-france.fr/index.html#/accueil)
D.9
Token value
protection
schemes
True
D.10
Token value
protection
schemes
As a MiCA compliant regula ted e-money token, USDC wi ll be fully ba cked by an equival ent amount of USD-
denominated assets held by Circle SAS with regulated financial instit utions in segregated accounts apart from
Circle SAS’s corporate f unds, on behalf of, and for the benefit of, USDC Holders.
description
D.11
Compensation
schemes
False
D.12
Compensation
schemes
description
Not applicable.
D.13
Applicable law
France
D.14
Competent court
Any dispute concerning the rights and obli gations of EEA residents arising out of the u se or ownership of
USDC shall be brought exc lusively to the Commerci al courts of Paris, Fra nce, except where provi ded
otherwise by Applicable Laws.
PART E - INFORMATION ON THE UNDERLYING TECHNOLOGY
E.1
Distributed ledger
technology
Not applicable as DTI i s provided in B.13
E.2
Protocols and
technical
standards
Circle has developed its technical e-money token specification for deploying USDC on Ethereum-Virtual-
Machine ("EVM") compatible base layers. This specification extends the existing ERC-20 fungible token
standard with additional core functionality required for Circle SAS, for example the blocklisting feature that
allows Circle SAS to prevent specific blockchain addresses from sending and receiving USDC.
For not natively EVM compati ble networks (Algorand, Aptos, Hedera, NEAR, Noble, Polkadot, Solana, Sui,
Stellar, XRPL, Flow, Tron), Circle SAS has assessed the existing availa ble Token Standards for each base
layer and deployed USD C on the Token Stand ard th at is best suited for Circle SAS’s specifications and
required functionality.
Blockchain
Token Standard
Algorand
ASA (Algorand Standard Asset s)
Aptos
Dispatchable Fungible Asset
Arbitrum One
ERC-20
Avalanche
ERC-20
Base
ERC-20
Celo
ERC-20
Codex
ERC-20
Ethereum
ERC-20
Flow (deprecated)
FungibleToken (Cadence). USDC on Flow was original ly
implemented using the C adence FungibleToken
standard, with Circle’s FiatToken contract including
extensions (pausable, blocklisting). Following Flow’s
“Crescendo” upgrade (September 2 024), the chain
tran sitioned toward ERC-20 compatibility, but Circle has
discontinued issuance; only redemptions remain
supported.
Hedera
Hedera Token
HyperEVM (Hyperliquid)
ERC-20
Ink
ERC-20
Linea
ERC-20
Monad
ERC-20
NEAR
NEP-141
Noble
FiatTokenFactory (Circle module)
Optimism
ERC-20
Plume
ERC-20
Polkadot Asset Hub
Polkadot Assets
Polygon PoS
ERC-20
Ripple (XRPL)
XRPL Fungible Token Standar d
Solana
SPL Token
Sonic
ERC-20
Stellar
Stellar Assets
Sui
RegulatedCoin
Sei
ERC-20
Tron (deprecated)
TRC-20
Unichain
ERC-20
World Chain
ERC-20
XDC
XRC-20
ZKsync Era
ERC-20
USDC is deployed using u pgradeable smart contrac t architectures via t he proxy patterns of th e Universal
Upgradeable Proxy Standar d (UUPS) – introduced via ERC-1822 – on Arbitrum, Avalanche, Base, Celo,
Ethereum, HyperEVM, Ink, Optimism, Plume, Polygon, Sei, Sonic, XDC and zkSync, and more generally, on all
EVM chains. These implementat ions allow the contra ct logic to be modifi ed without changing th e token
address. Aptos, Algorand, Hedera, NEAR, Noble, Polkadot, Sui, and Stellar’s nati ve token standards follow
their own upgradeable proxy model. The upgradeable smart contract architecture s include the UUPS proxy
pattern, allowing contract logic to be updated without changing the token address. Despite these additions, the
contracts preserve the expected ERC-20 behaviour, such as transfer, approve, and balance.
While USDC is available on 31 bloc kchain netwo rks ("USDC Supported Blockchai ns") to date, Circle will
likely add additional blockcha in support in the future and will update the list of USDC Supported B lockchains on
its Website.
Circle may, based on fac tors such as transacti on volumes or compliance considerations, deci de to discontinue
support for certain USDC Supported Blockchains. In such cases, the process for exchange or redemption by
USDC Holders on the affecte d blockchains w ill be published on Circle’s Website. As of the date of this White
Paper, the following b lockchains have alre ady been deprecated:
● Tron: Circle announced on February 21, 2024, that it would immediately cease minting USDC o n the
Tron blockchain. Transf ers to supported block chains and redemptions continue to be operate d for
USDC Holders.
● Flow: Circle announced in August 2024 that it would d iscontinue support for USDC on Flow due to the
chain’s “Crescendo” network upgrade (Circle blog). Minting stopped on August 27, 2024, and all
support ceased on September 3, 2024, when Circle froze remaining balances and began a manual
redemption process on Septembe r 4, 2024. Circle supports manual redemp tions for Flow USDC
holders who meet the eligibility criteria as outl ined in this Help Center article.
E.3
Technology used
USDC integrates with a ran ge of supporting techn ologies beyond its s mart-contract implementations. Circle
provides fiat on- and off-ramp functionality, transaction monitoring, and identity-verification workflows,
facilitating compliance-aligned integration s for exchanges, custodians, and fintech platforms.
On EVM-compatible networks, USDC is fully interoperable with the st andard JSON-RPC interface and
commonly used libraries such as Web3.js and Ethers.js, ensuring compatibili ty with Ethereum tooling. On non-
EVM blockchains, USDC intera cts through each chain’s native communication and SDK interfaces.
USDC metadata handling—relevant to contract interfaces, block explorers, token lists, and wallet
integrations—is impleme nted through established conventions. On EVM blockchains, USDC con tracts expose
the standard ERC-20 metadata functions. On non-EVM blockchains, basic metadata is also stored on-chain in
the smart-contract state (except as noted below):
● Algorand – on-chain via ASA parameters
● Hedera – on-chain in the native token object
● Noble – on-chain in the fiattokenfactory module
● Solana – USDC (legacy mint) keeps its metadata off-chain in the public Solana Token List JSON fil e¹,
while the newer EURC mint st ores metadata on-chain through the Metaplex Metadata Program
● Stellar – off-chain through a stellar.toml file hosted by Circle
● XRPL – off-chain through an xrp-ledger.toml file hosted by Circle
Because wallet integra tion is broadly supp orted—with USDC recognised and rendered by all major Web3
wallets—these conventions ensure consistent use r display and interaction across networks.
¹ Solana token-list entry: https://github.com/solana-labs/token-list/blob/main/src/tokens/sola na.tokenlist.json
E.4
Purchaser’s
technical
requirements
Circle Mint, Circle SAS’s service that allows its customers to access USDC directly from Circle SAS, is
currently only available to institutions located in supported jurisdictions. Circle Mint is subject to Circle SAS’s
Terms of Use.
The purchase of USDC on the secondary market, for exa mple, with EU-regulated trading platforms, is available
to all users of these third-party platforms. Most third-party trading and exchange services provided by regulated
crypto-asset service providers are open to retail customers as well and subject to their own compliance
requirements.
Prospective USDC Holders must use wallets compatibl e with the blockchain s on which USDC is native ly
issued.
Usage of USDC requires the USDC Holders to cover networ k fees, which may be gas fees on Ethereum, Layer
2s (Arbitrum One, Base, Ink, Linea, Polygon PoS, Optimism, Unichain, World Chain, zKSync Era) and other
EVM-compatible blockchains (Avalanche, Celo, Cod ex, HyperEVM, Monad, Plume, Sonic, Sei, XDC), and
transaction fees on other blockchains.
E.5
Consensus
mechanism
Not applicable as USDC i s a token and therefore does not have a consen sus mechanism. USDC runs on ba se
layers, which may be blo ckchains or layer-2 networks, in turn based on blockchains. Blockchains rely on
consensus mechanisms to ensure their decentralise d network of nodes can reach agreement around
transaction validity and ordering.
E.6
Incentive
mechanisms
and applicable
fees
Each blockchain we supp ort has developed its own incentive mechanis ms and request fees to re alise
transactions. Please refer to the website of ea ch of these blockchains for more details on the mechanisms in
place.
As of today, Circle SAS do es not take additiona l fees on these mechani sms.
E.7
Use of
distributed
ledger
technology
False
E.8
DLT functionality
description
Not applicable.
E.9
Audit
True
E.10
Audit outcome
Circle LLC, as a co-issuer of USDC and as technical provid er to Circle SAS, is r esponsible for ensuring th at its
smart contracts are developed in a safe and secure manner. As such, Cir cle works with industry leading
security auditing firms such as Chain Security, OtterSec, and others, t o audit every USDC smart contract prior
to launch or upgrade.
Any identified issue s during these audits are reviewed, valida ted, assessed and remedi ated according to thei r
severity prior to launch or upgrade.
As a matter of best practi ce and policy, Circl e SAS always open-sources every USDC smart contract that it has
deployed. This enables independent security researchers to verify the contract for any security vulnerabilities.
To enable responsible disclosure, Circle operates a p ublic vulnerabili ty disclosure program a nd a private bug
bounty program via HackerOne that enables vulnerabilities to be di sclosed to Circle.
As part of Circle SAS’s b lockchain due dili gence process when it e valuates deploying USDC on new
blockchains, Circle SAS requires independent security audits to be per formed on the blockchains themselves.
As a matter of policy, a ll audit results ar e internally reviewe d, validated, assesse d, and remediated accord ing to
the severity of each finding. Any findings that m ay lead to loss of funds must be remed iated.
PART F - INFORMATION ON RISKS
F.1
Issuer-related
risks
As part of the USDC issuanc e process, Circle SAS is exposed to several ri sks:
1. Bankruptcy Risks. This is the ri sk of Circle SAS going bankrupt, which could result from the insolv ency
of Circle SAS as part of its activities, the fai lure of a bank holding Circle SAS own funds or USDC
reserves, or other systemic financial risks that c ould impact the operations and financial solvency of
Circle SAS.
2. Third-Party Risks. This is the r isk Circle SAS faces in its business relati onships with one or mor e third
parties. The ability of Circle SAS to properly carry out its activities relies on the functioning of services
provided by several third parties, such as banks providing safeguardi ng and settlement accounts. The
inability of these third-party service providers to carry out their services could affect Circle SAS’s ability
to properly issue, manage, and redeem USDC. Third parties can elect to support US DC on their
platforms without any authorisation or approval by Circle SAS or anyone else. As a result, USDC
support on any third-party platform does not imply any endorsement by Circle SAS that such third-party
services are valid, legal, stable or otherwise appropriate. Circl e SAS is not responsible for any losses or
other issues encountered using USDC on third-party platforms.
3. Market Risks. This is the risk that USDC Reserve s may include assets th at are not guaranteed t o be
readily saleable (such as certain short-term financial securities). In that case, if there is an exceptionally
high demand for redemption of USDC, Circle SAS may not be able to fulfill all the redemption requests
within the timeframe prov ided for in the Redempti on Policy.
4. Risk of Loss. This is the ri sk of loss caused by f raud, theft, misuse, neg ligence, or improper
administration of USDC or the USDC Reserves.
5. Dual-issuer Risk. This is the risk that Circl e LLC may not be able, t emporarily or permanentl y, to
rebalance all or part of the USDC Reserves to Circle SAS, in the event that holdings and redem ptions
of USDC shift significantly towards the EEA, impacting Circle SAS’s abili ty to cover redemption
requests.
6. Anti-Money Laundering/Co unter-Terrorism Financing Risks ("AML/CTF"). Thi s is the risk that
crypto-asset wallets holding USDC or transactions in USDC may be used for money laundering or
terrorist financing purposes, or identified to a person known to have committed such offe nses.
7. Personal Data Risks. This is the risk that the persona l data of Circle SAS cus tomers may be leaked or
stolen due to a security breach.
8. Risks Related to Circle SAS’s Bus iness Activities and Industry. This is the risk that resu lts from
Circle SAS operating in a rapidly changing, regulatorily fragment ed, and highly competi tive industry.
9. Legal and Regulatory Risk. Circle SAS is subject to numerous laws and regulations, and may fail to
comply with such laws and regulatory requirements of the jurisdi ctions that Circle SAS operates in.
Further, Circle SAS could be subjected to inve stigations, enforcement actions, and penalties. Circle
SAS could also be subje ct to private litig ation.
10. Internal Control Risk. Any failure to de velop or maintain effe ctive internal contr ols, or any difficul ties
encountered in the implementation of such controls or their improvement, could harm Circle SAS’s
business, causing Circle SAS to have to report such failures and l ead to a loss of trust in the business.
11. Environmental, Social, and Governance Risks. Circle SAS issues USDC on various public
blockchains which use different consensus algorithms. Each public blockchain, depending notably on its
consensus algorithm, has certain environmental impacts. Please see Section G bel ow for sustainability
disclosures for USDC on each individual blockchain. USDC is not issued on blockchains usi ng the most
energy-intensive proof-of-work consensus mechanism, and the blockcha ins currently support ed by
Circle SAS generally us e Proof-of-Stake (or a modified vers ion of that mechanism), t he environmental
impacts of which are ve ry limited compared to P roof-of-Work. In the fut ure, enviro nmental regu lations
affecting consensus mechanisms may restrict Circle SAS’s ability to issue USDC on individual public
blockchains if their sustainability impact is consider ed too negative.
12. Outsour cing Risk. This is the risk that Circle SAS becomes structurally dependent on Circle LLC for
critical services.
F.2
Token-related
risks
1. Financial Stability Risks. Since USDC is a major stablecoi n that is used by and integrated in many
significant market infrastructures (e.g. crypto-asset trading platfor ms), a problem affecting USDC could
indirectly impact these inf rastructures and cause temporary instability.
2. Secondary Market Price Dislocati on Risk. This is the risk tha t the market value of USDC o n the
secondary market is not stable compared to the USD. This price dislocati on could be caused by various
factors, such as under-collateralisation risk and secondary market liquidity risk (see below).
3. Risk of Under-Collateralisation. This is the risk that, du e to fraud or mismanagement (by either Circle
SAS, Circle LLC, or a thi rd-party provider), the value of the reserve of assets backing the redeemability
of USDC becomes lower than the outstanding quantity of USDC. That risk would l ikely cause a price
dislocation of the market value of USDC (see above) and affect the ability of Circle SAS to redeem
holders at par or in a timely manner.
4. Liquidity Risk. This is the r isk that the USDC Reserves may include assets that are not readily
liquidated (such as certain short-term financial securities) or any technica l and operational issues causing
delays and liquidity ri sk (e.g. loss of APIs or corr espondent issues). In that case, if there is an exceptionally
high demand for redemption of USDC, Circle SAS may not be able to fulfill all the redemption requests
within the timeframe prov ided by the Redemption Po licy. Such risk coul d also cause a second ary
market price ris k (see above).
5. Scam Risks. This is the risk of loss resulting fr om a scam or fraud suffered by USDC Holders from
other malicious actors. These scams include – but are not limited to – phishing on social networks or by
email, fake giveaways, identity theft of Circle SAS or it s execu tive members, creation of fake USDC
tokens, offering fake USDC airdrops, amo ng others.
6. Taxation Risks. The taxation re gime that applies to USDC purchases and sales by either individual
holders or legal entities will depend on each holder’s jurisdiction. Circle SAS cannot guarantee that
conversions of fiat currency against USDC, or conversions of other cryp to-assets against USDC, will
not incur tax consequences. In addition, USDC Holders should be warned that, based on the current
provisions of MiCA, USDC could qualify both as a crypto-asset and as electroni c money. Which legal
classification prevails might vary amongst national competent author ities and will likely impact the tax
treatment of USDC transactions within the EE A.
7. Legal and Regulatory Risk. This ris k stems from the fact that e-money tokens and crypt o-asset
services are unregulated in certain jurisdictions out side of the EEA. There is also a lack of regulatory
harmonisation and cohesion globally which could lead to diverging r egulatory frameworks globally
and/or an evolution of EU e-money token an d crypto-asset rules in the futur e.
F.3
Technology-
related risks
Purchasing and using USDC may also expose the holder to technological risks.
1. Blockchain Risks. One or sev eral of the blo ckchain network(s) on which USDC i s issued may be
subject to technical vulnerabilities and be exposed to at tacks that could lead to a general network
disruption, such as unexpected pauses in transactions, inabili ty to proceed with transfers of USDC,
major losses for network partici pants, or unexpect ed liquidity mov ements.
2. Smart Contract Risks. The smart co ntracts deployed by Ci rcle SAS to mint or burn USDC on the
various blockchains or to ensure the transfer of USDC (notably t o other blockchains) may be exposed
to technical vulnerabilities that could lead to losses for US DC Holders.
3. Settlement Finality or Irrevoca bility of Blockchain Transactions. Depending on the tools a nd
services providers used to initiate USDC transactions, these tr ansactions may be irreversible. Once you
send USDC to a blockchain address, you accept the risk that you may lose access t o, and any claim
on, that USDC indefinitely or permanently. For example: (i) a bl ockchain address may have been
entered incorrectly and the true owner of the address may never be discovered, (ii) you may not have
(or may subsequently lose) the private ke y associated with such address, (iii) a blockcha in address may
belong to an entity that will not return the USDC, or (iv) a blockchain address may belong to an entity
that may return the USDC, but first requires ac tion on your part, such as verification of your iden tity.
4. Personal Data Risks. Pursuant to the General Data Protection Regulation ("GDPR"), Circle SAS is
required to take all necessary precautions: (i) with re gard to the nature of the data collected and the
risks presented by the processing of su ch data, (ii) to preserve the security of USDC Ho lders' personal
data and, (iii) in particular, to prevent such data from being distorted, damaged, or accesse d by
unauthorised third parties.
5. Unanticipated Risks. E-money tokens s uch as USDC are a relatively new and untested techn ology. In
addition to the risks included in this section, there might be other risks that cannot be foreseen.
Additional risks may a lso materialize as un anticipated variati ons or combinati ons of the risks discussed
within this section.
F.4
Mitigation
measures
Regarding the differen t risks identified in Sections F1, F2 and F3, Circle SAS implements app ropriate
measures to mitiga te these risks a nd protect its customers, as fol lows:
1. Mitigation measure s concerning issue r-related risks
Circle SAS has implemented a comprehensive Risk Manag ement and Internal Contro l Framework grounded in
the Three Lines of Defense model. The first line, comprising business and operational team s, owns and
manages risks in d ay-to-day activities. The second l ine, composed of compliance, security and risk
management functions, provides indepe ndent oversight a nd ensures polici es, controls, an d processes are
robust and effective. The third line, internal audit, cond ucts independent assessments o f the control
envi ronment. Circle SAS performs regular and proa ctive risk assessments to identify, evaluate, a nd address
evolving threats and vulnerabilities. The company enforces a permanent control system that includes regular
testing, incident tracking, and corrective action follow-ups. Ongoing training and awareness initiatives further
embed a strong risk culture across the organization, ensuri ng that staff remain vigilant and empowered to
uphold the highest standards of integrity and compliance.
Specific mitigations for each of the risks are as follows:
1.1. Bankruptcy Risks. While there is no legal prec edent, Circ le SAS's ban kruptcy shou ld have no impact on
the rights of USDC Holders. If Circle SAS goes ba nkrupt, the USDC Reserves are protec ted by Applicable Law
and cannot be used to compensate Circle SAS’s other creditors. Bank accounts used by Cir cle SAS for the
USDC Reserves are safeguarde d from Circle SAS creditor s as provided by Appli cable Law. Any USDC will be
refunded to its holders as part of Circle SAS's ba nkruptcy proceedings, without the holder n ecessarily having to
file a claim for compensation.
1.2. Third-party Risks. When Cir cle SAS reli es on a thi rd party to provide se rvices that are import ant to
USDC, Circle SAS generally enters into an agreement containing specifi c clauses ensuring th at the service
provider cannot terminate the business relationship without advanced notice. Some of these agreements (such
as the agreements concerning the safeguarding accounts used to invest t he USDC Reserves) are also subject
to regulatory obligations. In addition, Circle SAS impleme nts internal procedures who se purpose is to limit
disruption in the event that an important service pr ovider terminates an agreement or becomes unable to
provide its services to Circle SAS. Finally, third part ies with whom Circle SAS contracts are subject to due
diligence procedures to ensure their financial viability and to limit any other risks of non-compliance. To further
mitigate dependency risk, Circle SAS applies a div ersification st rategy, aiming t o avoid excessive concentration
with any single banki ng, custody, or operat iona l partner. This inc ludes maintaining relationsh ips with multiple
safeguarding institutions and service providers where feasibl e, regularly assessing diversification metrics, and
establishing contingency options to ensure operational continui ty in the event of a third-party failure or service
interruption.
1.3. Market Risks. Circle SAS’s systems and procedur es are set up in a way that ensures that USDC
redemptions will occur in the timeframe set out in th e Redemption Policy, even if volatility in crypto-asset
markets causes a si gnificant incre ase in redemption requests.
1.4. Dual Issuer Risk. USDC is full y fungible globall y and Circle France’s Minimum Reserve Requirement i s
equal to EEA holdings of USDC at all times. The USDC Reserves Rebalancing Procedure and related
contractual agreement ensures that both entities will r ebalance their respect ive reserves in the eve nt that such
requirement is not met. The Circle SAS Reco very Plan and Redemption Plan will take into acc ount these intra-
group considerations and outline a uniform and coordinated approach by both issuers in order to be able to
cover any outstanding liabilities and satisfy redemptions in a prompt and equitable way.
1.5. Risks of Loss. The redemption right of eligi ble USDC Holders remains ex ercisable even if Ci rcle SAS
suffers a loss at the level of the safeguarded assets. As is required under Applicable Law, Circle SAS is well-
capitalised and funded and, as an electronic money institut ion, Circle SAS is subject to regulatory capital and
own-funds requirements. In the event tha t the loss should exceed Circle SAS’s ability to redeem the USDC
Holders, the Redemption Pl an may be triggered to ensure equitable trea tment of all USDC Holders.
1.6. AML/CFT Risks. Each USDC redemption r equest to Circle SAS requ ires the holder to co mply with the
laws and regulations applic able to anti-money laundering and counter-terrorist financing in the EU. Moreover, if
Circle SAS determines that USDC transactions linke d to publi c addresses are likely to be associated with
criminal offenses, Circle SAS may decide to freeze the associated USDC (temporaril y or permanently). Also, if
Circle SAS receives an i njunction from a compete nt authority to freeze USDC, Circle SAS will compl y with such
a request.
1.7. Personal Data Risks. Pursuant to the GDPR, Circle SAS is required to take all necessary preca utions
with regard to the natu re of the data and the risks presented by the processing of such da ta, to preserve the
security of USDC Holders' personal data and, in particular, t o pr event it from being distorted, damaged, or
accessed by unauthorised third parties.
2. Mitigation measure s concerning the token-related risks
2.1. Financial Stability Risks. USDC ha s been issued since 2 018 and has withstood s everal major volatil ity
events and liquidity crises. Circle SAS’s internal procedures such as robust Reserve Management policies,
diversification of banking partners, periodic reconci liation, business con tinuity and risk management framework
ensure that USDC can reliably be used by market participants and market i nfrastructures under all market
conditions.
2.2. Secondary Market Price Disloca tion Risk. Circle SAS expects t hat any disparity bet ween the USDC
price and USD on secondary markets would be promptly resolved by market participant s (i.e. buying USDC for
less than 1 USD on th e secondary market and redeeming it at par valu e with Circle SAS), a s any participant
will be entitled to redeem at par with Circl e SAS. Otherwise, if the p rice dislocation i s caused by an inadequ acy
of the USDC Reserves or other liquidity issues, Circle SAS will apply t he measures set out in its Recovery Plan
or Redemption Plan.
2.3. Risks of Under-Collateralisation. If the USDC Reserves become lower than the outstanding quantity of
USDC in circulation, Ci rcle SAS may apply measures set out in its Contin gency Funding Plan, Reco very Plan
or Redemption Plan. These plans include measures that could resolve the under-coll at eralisation through for
example backstoping any loss incurred within the USDC reserve with Circle’s own cor porate assets.
2.4. Liquidity Risk. Circle SAS has i mplemented a Redemption Pol icy designed to ensur e the prompt
redemption of USDC and to respond to scenarios of extreme demand for red emption in unfavorable market
conditions. Circle also looks to expand its settlement banki ng footprint wit h major banking partners to limit
Liquidity Risk.
2.5. Scam Risks. Circle SAS canno t prevent all attempts to defraud or scams in c onnection with USDC. The
general terms and conditions relating to USDC issuance specify that Cir cle SAS is not liable for this type of
loss. From time to tim e, Circle SAS will infor m its client s of such risks through various channels.
2.6. Taxation Risks. The tax conseq uences of USDC transaction s should be assessed a t the level of each
USDC holder. It is the so le responsibility of USDC Holders to address taxation risks in co nsideration of their
personal situation. Circle SAS and its affiliates does not pro vide, nor accept responsibility for, any legal, tax or
accounting advice. If USDC Holders are unsure regarding any of the legal, tax or accounting aspects of their
situation regarding USDC, they should seek independent professional advice.
3. Mitigation measure s concerning techn ology-related risks
3.1. Blockchain related Risks. Whil e risks ex ist for all blockchai n networks, blockchain networks us ed by
Circle SAS to issue USDC are recognised for their high level of secur ity and have generall y withstood several
major events with out any interrup tion to their normal functionin g. Befo re launching USDC on any new
blockchain, Circle SAS conducts thorough due diligence, including blockchain-level security audits, as w ell as
the review of the history of the blockchain, the lev el of decentralisation, and the degree of resilience or activity
on the network.
3.2. Smart Contract Risks. To reinforce the resilience of t he smart contracts for USDC i ssuance, Circle SAS
is making the contract a ddresses linked to USD C issuance open-source so that anyone can consult them and
alert Circle SAS in the event of a default. The code source of the smart contracts is publicly available in real
time. In addition, each smart contract relating to U SDC issuance has been audited. In the event of a
modification to the source code, the smart contrac t is audited aga in to ensure tha t no potential security exploit
can be used to fraudulently use the USDC mint or burn system or to ci rcumvent its initial use by other means.
More specific inf ormation on the audits carried o ut on the USDC i s detailed in Se ction E.3.
3.3. Settlement Finality or Irrevocabil ity of Blockchain Transactions. Circ le SAS cannot prevent
blockchain transactions from being irreversible and in many cases, will not be able to mitigate this risk, not ing
that irrevocability is also a major security element of bloc kchain networks. Circle SAS will not be held liable for
this type of loss. From time to time, Circle SAS will inform its clients of such risks through various channels o f
communication.
3.4. Security Program. Circle SAS is supported by a dedicated cybersecurity team tha t monitors the
technology environment 24/7, impleme nts multiple layers of security defenses, and p erforms ongoing security
scanning and testing
G – Information on the sustainability indicators in relation to adverse impact on the climate and other environment-related adverse impacts
Mandatory Information on principal adverse impacts on the climate
N
Field
Content
General Information
S.1
Name
Circle Internet Financ ial Europe SA
S.2
Relevant legal
entity identifier
969500OYUDADGZKCR583
S.3
Name of the
crypto-asset
USDC
S.4
Consensus
Mechanism
Not applicable as USDC i s a token and therefore does not have a consen sus mechanism. USDC runs on ba se layers,
which may be blockchain s or layer-2 networks, in turn based on blockchains. Blockchains rely on consensus
mechanisms to ensure their decentral ise d network of nodes can reach agreement around tr ansaction validity and
ordering.
S.5
Incentive
Mechanisms
and Applicable
Fees
Each blockchain we supp ort has developed its own incentive mechanis ms and request fees to re alise transactions.
Please refer to the webs ite of each of these b lockchains for more det ails on the mechanisms i n place.
As of today, Circle SAS do es not take additiona l fees on these mechani sms.
S.6
Beginning of
the period to
which the
disclosure
relates
2024-10-17
N
Field
Content
General Information
S.7
End of the
period to which
the disclosure
relates
2025-10-16
Mandatory key indicator on energy consumption
S.8
Energy
consumption
Base layer
kWh per calendar year
Algorand
1,038.31438
Aptos
0.96536
Arbitrum One
6,753.52664
Avalanche
2,606.71910
Base
56.74208
Celo
223.12948
Codex
0.00000
Ethereum
5,824.09616
Flow
18.59182
Hedera
0.00002
HyperEVM
0.50121
N
Field
Content
General Information
Ink
4.02577
Linea
0.78373
Monad
8.17312
NEAR
0.06994
Noble
2.38256
Optimism
8.92221
Plume
0.00051
Polkadot Asset Hub
6.70291
Polygon
6.55124
Sei
1.00375
Solana
72,811.73205
Sonic
868.67386
Stellar
617.64351
Sui
82.89684
Tron
5.46807
Unichain
1.72695
World Chain
0.01728
XDC
132.19690
N
Field
Content
General Information
XRPL
16.11411
ZKSync
0.00139
Total
91089.49979
Sources and methodologies
S.9
Energy
consumption
sources and
methodologies
Data provided by the MiCA Crypto Alliance as a t hird party, with no de viations from the calc ulation guidance of
Commission Delegated Regul ation (EU) 2025/422, Arti cle 6(5). As the base layers are decentrali sed networks,
estimates on individual node power d raw are used. Values for HyperEVM, Ink, Sei and XDC corresp ond to October
2025. Since the Monad blockchain is in the testnet and has not been launched, assumptions on future throughput of
USDC on Monad are made and thei r values are thus not included in the total field for S.8, S.10, S.11, S.12, S.13 and
S.14. Full methodology a vailable at: www.micacryptoall iance.com/methodologies
Supplementary Information on the principal adverse impacts on the climate and other environment-related adverse impacts of the
consensus mechanism
N
Field
Content
Supplementary key indicators on energy and GHG emissions
S.10
Renewable
energy
consumption
Base layer
Percentage (decimal)
Algorand
39.3002877244%
Aptos
36.7943144021%
Arbitrum One
44.0006804884%
Avalanche
35.3318926442%
Base
39.0326707634%
Celo
39.6545985875%
Codex
39.9412986134%
Ethereum
35.4272282688%
Flow
31.6736704539%
Hedera
38.7353382169%
HyperEVM
39.7914565339%
Ink
39.8716067977%
Linea
38.8770215445%
Monad
35.6673557073%
NEAR
39.0196302710%
Noble
39.8471533795%
Optimism
38.8349396075%
Plume
39.5299063929%
Polkadot Asset Hub
38.4185375915%
Polygon PoS
39.0139873629%
Sei
38.8269469969%
Solana
40.5646569227%
Sonic
39.8537573663%
Stellar
38.8450452475%
Sui
38.9885598088%
Tron
32.0154425345%
Unichain
39.8499456046%
World Chain
39.9321338066%
XDC
38.9145620574%
XRPL
36.4496554839%
ZKSync Era
38.8652936510%
Total
40.2976835448%
S.11
Energy intensity
Base layer
kWh per transaction
Algorand
0.0000762554
Aptos
0.0000007137
Arbitrum One
0.0000275328
Avalanche
0.0000283013
Base
0.0000001049
Celo
0.0000211845
Codex
0.0000000009
Ethereum
0.0000752403
Flow
0.0002029342
Hedera
0.0000000002
HyperEVM
0.0000000407
Ink
0.0000000538
Linea
0.0000000354
Monad
0.0000000395
NEAR
0.0000108718
Noble
0.0000003880
Optimism
0.0000000782
Plume
0.0000000237
Polkadot Asset Hub
0.0001754690
Polygon PoS
0.0000000388
Sei
0.0000000177
Solana
0.0000358439
Sonic
0.0000088492
Stellar
0.0000036917
Sui
0.0000011707
Tron
0.0000411904
Unichain
0.0000000279
World Chain
0.0000000266
XDC
0.0195422634
XRPL
0.0000010972
ZKSync Era
0.0000000187
Total
0.0000266610
S.12
Scope 1 DLT
GHG emissions
– controlled
Base layer
t CO2eq per calendar year
Algorand
0
Aptos
0
Arbitrum One
0
Avalanche
0
Base
0
Celo
0
Codex
0
Ethereum
0
Hedera
0
Linea
0
NEAR
0
Noble
0
Optimism
0
Polkadot Asset Hub
0
Polygon PoS
0
Solana
0
Sonic
0
Stellar
0
Sui
0
Unichain
0
World Chain
0
XRPL
0
ZKSync Era
0
Total
0
S.13
Scope 2 DLT
GHG emissions
– purchased
Base layer
t CO2eq per calendar year
Algorand
0.30636
Aptos
0.00029
Arbitrum One
2.06177
Avalanche
0.81646
Base
0.01682
Celo
0.06548
Codex
0.00000
Ethereum
1.85407
Flow
0.00574
Hedera
0.00000
HyperEVM
0.00015
Ink
0.00118
Linea
0.00023
Monad
0.83413
NEAR
0.00002
Noble
0.00007
Optimism
0.00265
Plume
0.00000
Polkadot Asset Hub
0.00199
Polygon PoS
0.00194
Sei
0.00030
Solana
20.39564
Sonic
0.25467
Stellar
0.18357
Sui
0.02461
Tron
0.00199
Unichain
0.00051
World Chain
0.00001
XDC
0.03930
XRPL
0.00480
ZKSync Era
0.00000
Total
26.04123
S.14
GHG intensity
Base layer
kg CO2eq per transaction
Algorand
0.0001257102
Aptos
0.0000002697
Arbitrum One
0.0000426190
Avalanche
0.0000495275
Base
0.0000001576
Celo
0.0000062165
Codex
0.0000000003
Ethereum
0.0001150340
Flow
0.0003500503
Hedera
0.0000000003
HyperEVM
0.0000000119
Ink
0.0000000157
Linea
0.0000000534
Monad
0.0000040289
NEAR
0.0000180257
Noble
0.0000001137
Optimism
0.0000001180
Plume
0.0000000070
Polkadot Asset Hub
0.0002906460
Polygon PoS
0.0000000584
Sei
0.0000000253
Solana
0.0000122291
Sonic
0.0000025943
Stellar
0.0000013858
Sui
0.0000004234
Tron
0.0000837295
Unichain
0.0000000082
World Chain
0.0000000078
XDC
0.0070764066
XRPL
0.0000018275
ZKSync Era
0.0000000282
Total
0.0000076220
Sources and methodologies
S.15
Key energy
sources and
methodologies
Data provided by the MiCA Crypto Alliance as a t hird party, with no de viations from the calc ulation guidance of
Commission Delegated Regul ation (EU) 2025/422, Arti cle 6(5). Since the Mon ad blockchain is in the testnet and has
not been launched, assumptions on future throughput of USDC on Monad are made and their values are thus not
included in the total field f or S.8, S.10, S.11, S.12, S.13 and S.14. Values for HyperEVM, Ink, Sei and XDC correspond
to October 2025.
Full methodology avail able at: www.micacryptoallian ce.com/methodologies
S.16
Key GHG
sources and
methodologies
Data provided by the MiCA Crypto Alliance as a t hird party, with no de viations from the calc ulation guidance of
Commission Delegated Regul ation (EU) 2025/422, Arti cle 6(5). Since the Mon ad blockchain is in the testnet and has
not been launched, assumptions on future throughput of USDC on Monad are made and their values are thus not
included in the total field f or S.8, S.10, S.11, S.12, S.13 and S.14. Values for HyperEVM, Ink, Sei and XDC correspond
to October 2025.
Full methodology avail able at: www.micacryptoallian ce.com/methodologies