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[ENTITY FILE] SUBJECT-29187 COMPANY ACTIVE
CF
// Subject

Circle Internet Financial​‍‍​‍‍​‌​‌‌​‍‌​‍​‌‍‍​​​‍​​‍​‍​

Issuer of USDC stablecoin; NYSE-listed (CRCL) as of June 2025
Tracked Second-largest stablecoin issuer; reserve-management contract with BlackRock creates a direct fee pipeline from stablecoin float to a politically active asset manager. Public-company status post-IPO means new disclosure obligations to monitor.
// Editorial summary — AI-generated from public records

Circle issues USDC, the second-largest dollar stablecoin. Reserves are largely managed by BlackRock via the Circle Reserve Fund. Completed its IPO on the NYSE in June 2025 under ticker CRCL.

Facts on record17
Connections mapped1
Sources cited1
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Stated vs Revealed (1)
Stated vs Revealed Statement vs disclosure · date gap
Stated · 2024
Circle publicly campaigned for the repeal of SAB 121 and for passage of the GENIUS Act stablecoin framework, both of which materially expand its addressable market.
Revealed · 2024
Circle's S-1 filing disclosed that interest income on reserves accounted for the substantial majority of total revenue, making the company's economics directly geared to short-term U.S. interest rates.
Gain · Regulatory win Circle's public framing of its lobbying is regulatory clarity for stablecoin users; its own S-1 discloses that the substantial majority of revenue is interest income on reserves — i.e. the legislation it lobbied for protects the yield-extraction business model rather than the consumer-protection goal cited in its public messaging.→ money-flow chain #1993
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Documented financial relationships span 1 money flow chain.
1Money Chains
2Traced Hops
Calculation Methodology

Contract values are summed from documented money flow chains where this entity appears as a source or destination node. Amounts are drawn from USASpending.gov, FEC filings, SEC EDGAR, or LD-2 lobbying registrations.

Donor contributions aggregate documented amounts from the donor_interests table, sourced from FEC individual and PAC contribution filings.

Connected officials are elected officials in our database with a mapped relationship (lobbying, board membership, campaign contribution, etc.) to this entity.

Annualised flow represents the total documented dollar amount traced through money flow hops involving this entity. Where hop-level amounts are unavailable, the chain-level documented total is used as a conservative upper bound.

All figures are drawn from public filings. Estimates are conservative — undisclosed transactions, dark money, and vanish-point hops are excluded from totals. This is a minimum documented floor, not a ceiling.

Connection Map
Key Connections
← Entity #25
reserve-management
BlackRock manages the Circle Reserve Fund, which holds the bulk of USDC reserve assets.
Facts (17)
Data Freshness
Fresh Last update: 4d ago · Avg age: 4d
Confidence Tiers: Primary Source — cross-referenced government/corporate filings Pending Review — sourced but not independently verified AI Inference — analytical hypothesis from cross-referencing
✓ Verified Findings (3)
These facts have been cross-referenced and confirmed against their source material.
Verified Pending Review Evidence gap: Circle's lobbying expenditure attributable specifically to GENIUS Act and S​‍‍​‍‍​‌​‌‌​‍‌​‍​‌‍‍​​​‍​​‍​‍​AB 121 advocacy is bundled with general financial-services lobbying in disclosure filings.
Added: 03 May 2026
Verified Pending Review Evidence gap: The split of yield income retained by Circle versus passed through to ​‍‍​‍‍​‌​‌‌​‍‌​‍​‌‍‍​​​‍​​‍​‍​USDC redemption infrastructure (e.g. partner exchanges) is not separately disclosed.
Added: 03 May 2026
Verified Pending Review Evidence gap: The exact fee schedule BlackRock charges Circle for managing the reserve fund ha​‍‍​‍‍​‌​‌‌​‍‌​‍​‌‍‍​​​‍​​‍​‍​s not been disclosed in either company's public filings beyond general expense-ratio language.
Added: 03 May 2026
Raw Filing Records (14) — unsourced metadata
Pending Review The Circle Reserve Fund (USDXX) reported a 7-day SEC yield of 3.59% as of May 1, 2026, reflecting a 0.17% net expense ratio after contractual fee waivers by BlackRock.
Date: 2026-05-01 Added: 03 May 2026
Pending Review Senators Thom Tillis and Angela Alsobrooks finalized a 'stablecoin yield' compromise for the CLARITY Act on May 1, 2026, which prohibits rewards that are 'economically or functionally equivalent' to bank interest.
Date: 2026-05-01 Added: 03 May 2026
Pending Review On May 1, 2026, BlackRock submitted a formal comment letter to the OCC opposing a 20% cap on tokenized reserve assets and requesting that Treasury ETFs be designated as 'eligible reserves' under the GENIUS Act.
Date: 2026-05-01 Added: 03 May 2026
Pending Review The OCC's proposed 'Part 15' regulations (Feb 2026) create a 'rebuttable presumption' that yield paid by an exchange affiliate to a stablecoin holder is an evasion of the GENIUS Act's interest prohibition.
Date: 2026-02-25 Added: 03 May 2026
Pending Review Circle reported a total net loss of $70 million for FY 2025 despite generating $2.75 billion in total revenue, primarily due to a 74% year-over-year surge in distribution and compensation expenses following its IPO.
Date: 2026-02-26 Added: 03 May 2026
Pending Review Coinbase captured approximately 80% ($1.35B) of Circle's total distribution payments (estimated $1.68B) in FY 2025, leaving only ~$330M for all other global distribution partners and transaction costs.
Date: 2026-02-24 Added: 03 May 2026
Pending Review Circle reported total revenue and reserve income of $2.7 billion for fiscal year 2025, with distribution costs reaching $461 million, significantly driven by revenue-sharing agreements enabled by the GENIUS Act's yield structure.
Date: 2026-02-25 Added: 03 May 2026
Pending Review The GENIUS Act (S. 1582) became Public Law 119-27 on July 18, 2025, establishing the first federal regulatory framework for payment stablecoins.
Date: 2025-07-18 Added: 03 May 2026
Pending Review USDC outstanding supply has fluctuated between roughly $25B and $60B during 2023-2025, generating reserve-investment yield that funds the bulk of Circle's revenue.
Date: 2024 Added: 03 May 2026
Pending Review Circle publicly campaigned for the repeal of SAB 121 and for passage of the GENIUS Act stablecoin framework, both of which materially expand its addressable market.
Date: 2024 Added: 03 May 2026
Pending Review Circle's S-1 filing disclosed that interest income on reserves accounted for the substantial majority of total revenue, making the company's economics directly geared to short-term U.S. interest rates.
Date: 2024 Added: 03 May 2026
Pending Review BlackRock manages the Circle Reserve Fund, a registered government money market fund holding the bulk of USDC's dollar reserves; the relationship was formalised in 2022.
Date: 2022-11-03 Added: 03 May 2026
Pending Review BlackRock manages the Circle Reserve Fund, which holds the bulk of USDC's dollar reserves and earns BlackRock management fees scaled to USDC outstanding supply.
Date: 2022 Added: 03 May 2026
Pending Review Circle Internet Financial began trading on the NYSE under the ticker CRCL on 5 June 2025, in one of the largest financial-services IPOs of the year.
Date: 2025-06-05 Added: 03 May 2026
All Connections (1)
← Entity #25
reserve-management primary since 2022
BlackRock manages the Circle Reserve Fund, which holds the bulk of USDC reserve assets.
Money Flows Passing Through (1)
Documented payment chains where this entity appears as a source, hop, or vanish point. All chains →
active 4 hops ⚠ 1 vanish
Circle USDC reserves → BlackRock fund fees → BlackRock political spend → SAB 121 reversal
Sources (1)
— ↗ Circle lobbying — OpenSecrets news Raw