Nils Silinevics
Partner · AML & Crypto Compliance · Former FIU Investigator
Circle (USDC) is a stablecoin issuer with freeze authority over your tokens. Circle is FinCEN-registered (MSB); NY DFS limited purpose trust; SEC-regulated Swiss lawyers file formal appeals with Circle (USDC)'s compliance team. Free case review within 24 hours.
Circle is FinCEN-registered (MSB); NY DFS limited purpose trust; SEC-regulated
USA has fragmented regulation — FinCEN (MSB registration), SEC (Howey test: is it a security?), CFTC (commodities), state regulators (NY BitLicense is most famous)
This matters because it determines which regulatory body has authority over your case — and whether you have a direct complaint path or need cross-jurisdictional legal action.
What this means for you: Circle (USDC) is a stablecoin issuer with freeze authority. The freeze is at the smart contract level — not an exchange freeze. We appeal directly to Circle (USDC)'s compliance team and coordinate with FinCEN (federal MSB) + SEC (securities) + CFTC (derivatives) + state regulators (NY DFS BitLicense) if the freeze is related to a regulatory request.
under BSA, you can complain to FinCEN; state regulators (e.g., NY DFS for BitLicense firms); SEC whistleblower program; CFTC reparations
Under Bank Secrecy Act (BSA) + USA PATRIOT Act + FinCEN regulations (31 CFR Chapter X), Circle (USDC) must conduct customer due diligence and can freeze accounts during AML investigations. However, they must also:
If Circle (USDC) doesn't meet these obligations, we escalate to FinCEN (federal MSB) + SEC (securities) + CFTC (derivatives) + state regulators (NY DFS BitLicense) and file a formal legal submission. For a broader comparison of how United States's rules stack up against other jurisdictions, see our AML laws by country reference.
capital gains tax (0/15/20% federal + 3.8% NIIT) + state income tax; income tax if mining/staking
If your Circle (USDC) account is frozen, you may still need to declare your crypto holdings on your United States tax return — even if you can't access them. Under United States law, the tax obligation may apply regardless of whether the funds are accessible. We recommend consulting a American tax advisor.
If the freeze causes you to miss a tax deadline, we can provide documentation for the FinCEN (federal MSB) + SEC (securities) + CFTC (derivatives) + state regulators (NY DFS BitLicense) and tax authority explaining the situation.
A American user's address was blacklisted by Circle (USDC) after receiving funds from a flagged source. Circle (USDC) froze the address on-chain. Under Bank Secrecy Act (BSA) + USA PATRIOT Act + FinCEN regulations (31 CFR Chapter X), Circle (USDC) has freeze authority. We filed a formal appeal with Circle (USDC)'s compliance team and coordinated with FinCEN (federal MSB) + SEC (securities) + CFTC (derivatives) + state regulators (NY DFS BitLicense). Within 14 days, Circle (USDC) released the funds after our submission demonstrated compliance with Bank Secrecy Act (BSA) + USA PATRIOT Act + FinCEN regulations (31 CFR Chapter X).
Details anonymized to protect client confidentiality. Swiss professional secrecy applies.
We analyze your Circle (USDC) account, transaction history, and United States regulatory context to identify the exact trigger. Was it a TRM Labs risk flag? A sanctions screening match? A source-of-funds demand? Each requires a different strategy.
We prepare documentation compliant with Bank Secrecy Act — not just Circle (USDC)'s standard templates. This includes source-of-funds proof, transaction tracing, and any required FinCEN-specific forms.
We submit through Circle (USDC)'s compliance channels — not standard support. Our submission is in English and references FinCEN guidelines. We coordinate with FinCEN even though Circle (USDC) is not registered.
We verify everything works and advise on preventing recurrence on Circle (USDC). If Circle (USDC) doesn't respond within no statutory maximum; FinCEN expects SAR (Suspicious Activity Report) resolution within 30-90 days, we escalate to FinCEN and pursue cross-jurisdictional action in USA (Boston, MA) if needed.
Tell us what happened. A senior crypto compliance lawyer — not a chatbot, not a junior — will read your case and respond within 6 hours. Swiss professional secrecy applies from your first message.