SUBJECT-29187.dossier · company · status: active
CF
subject of file

Circle Internet Financial

Issuer of USDC stablecoin; NYSE-listed (CRCL) as of June 2025
Tracked because 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-drafted 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 record18
Connections mapped11
Sources cited12
Inferential claims1
Evidence: 11P+3 3S 4I
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Stated vs Revealed (1)
Stated vs Revealed Statement vs disclosure · date gap
Stated · 2024-06-15
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 · 2024-06-15
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
PROVE IT
[PUBLIC COST ESTIMATE]
Documented financial relationships span 1 money flow chain, while 10 elected officials hold documented connections.
1Money Chains
2Traced Hops
Connected Officials
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.

PATTERN organization → [donor] → elected official → [potential co... 324× PATTERN organization → [donor] → elected official → [industry reg... 196× PATTERN company → [Legislative Relationship] → elected official →... 180× PATTERN organization → [donor] → elected official → [Legislative ... 180× PATTERN company → [competitor] → company → [investor] → company 168×
Connection Map
Key Connections
← BlackRock company
reserve-management
BlackRock manages the Circle Reserve Fund, which holds the bulk of USDC reserve assets.
→ Coinbase company
Revenue/Distribution Partner
Coinbase captured approximately 80% ($1.35B) of Circle's total distribution payments (estimated $1.68B) in FY 2025.
→ GENIUS Act instrument
Legislative Impact
The GENIUS Act (S. 1582) became Public Law 119-27 on July 18, 2025, establishing the first federal regulatory framework for payment stablecoins, which materially expanded Circle's addressable market and enabled its revenue-sharing agreements.
← Tim Scott elected official
post-enactment briefing coordination
In March 2026, the Senate Banking Committee's new GOP Staff Director (appointed under Scott's chairmanship) initiated non-public implementation briefings with Circle to coordinate the rollout of the CLARITY Act yield-rewards compromise.
Facts (18)
Data Freshness
Ageing Last update: 147d ago · Avg age: 212d
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 (14)
Independently re-checked: a second model read the source artifact and confirmed it supports the extracted claim.
✓ verified 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
✓ verified 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
✓ verified 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
✓ verified 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
✓ verified 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
✓ verified 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
✓ verified 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
✓ verified 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
✓ verified 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: 2024-06-15 Added: 03 May 2026
Partially Corroborated 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: 2024-06-15 Added: 03 May 2026 ↗ SOURCE: Circle lobbying — OpenSecrets
Primary Source 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.
Primary Source 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.
✓ verified 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: 2022-06-15 Added: 03 May 2026
✓ verified 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
AI Analysis (1)
AI-generated inferences derived from cross-referencing primary and secondary data. These are analytical hypotheses, not established facts — they are the platform's read, not its record, and the verification pipeline covers their provenance, not their truth. Where verification stops →
⚠ flagged by Gemini AI Inferencew·40 Circle Internet Financial filed filing with the SEC on 2025-08-12. Accession number: N/A.
All Connections (11)
→ Coinbase company
Revenue/Distribution Partner primary since 2025
Coinbase captured approximately 80% ($1.35B) of Circle's total distribution payments (estimated $1.68B) in FY 2025.
→ GENIUS Act instrument
Legislative Impact primary since 2025
The GENIUS Act (S. 1582) became Public Law 119-27 on July 18, 2025, establishing the first federal regulatory framework for payment stablecoins, which materially expanded Circle's addressable market and enabled its revenue-sharing agreements.
oversight inferential since 2025
Circle publicly campaigned for the repeal of SAB 121, which materially expands its addressable market.
→ Angela Alsobrooks elected official
Legislative Relationship inferential since 2026
Senator Angela Alsobrooks helped finalize a 'stablecoin yield' compromise for the CLARITY Act on May 1, 2026, which is part of the regulatory framework affecting Circle's business.
← BlackRock company
reserve-management primary since 2022
BlackRock manages the Circle Reserve Fund, which holds the bulk of USDC reserve assets.
← Troy Downing person
potential regulatory connection inferential since 2025
Downing serves on the Digital Assets/FinTech/AI Subcommittee of House Financial Services, which oversees stablecoin issuers like Circle. No direct documented interaction.
← Tim Scott elected official
post-enactment briefing coordination primary since 2026
In March 2026, the Senate Banking Committee's new GOP Staff Director (appointed under Scott's chairmanship) initiated non-public implementation briefings with Circle to coordinate the rollout of the CLARITY Act yield-rewards compromise.
← Cynthia Lummis elected official
potential_consultation secondary since 2025
Evidence gap exists regarding internal communications between Lummis's office and Circle counsel during the GENIUS Act and SAB 121 processes.
← Kirsten Gillibrand elected official
industry_regulatory_context inferential since 2025
Gillibrand's stablecoin legislation (GENIUS Act) directly impacts stablecoin issuers including Circle.
← Tether company
competitor inferential since 2024
Tether's USDT ($110B+ outstanding) is the largest dollar-pegged stablecoin, directly competing with Circle's USDC in the stablecoin market.
← Fairshake PAC organization
donor inferential since 2024
Circle (USDC issuer) is a crypto company that has contributed to Fairshake PAC according to public reports, though not documented in the provided facts specifically.
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 (12)
2026-03-09 ↗ SEC EDGAR: filing — Circle Internet Financial (2026-03-09) sec_filing Processed 📜 Receipt
2026-05-22 ↗ SEC EDGAR: filing — Circle Internet Financial (2026-05-22) sec_filing Processed 📜 Receipt
— ↗ Circle lobbying — OpenSecrets news Raw 📜 Receipt
2025-04-01 ↗ SEC EDGAR: filing — Circle Internet Financial (2025-04-01) sec_filing Processed 📜 Receipt
2025-08-12 ↗ SEC EDGAR: filing — Circle Internet Financial (2025-08-12) sec_filing Processed 📜 Receipt
2026-05-09 UNVERIFIED SEARCH_ERROR: Circle Internet Financial not found in opencorporates claim_flag Processed 📜 Receipt
2026 UNVERIFIED Research: Circle Internet Financial — Corporate registrations (no results) government_disclosure Processed 📜 Receipt
2026 UNVERIFIED Research: Circle Internet Financial — Parliamentary records (no results) parliamentary_record Processed 📜 Receipt
2026 UNVERIFIED Research: Circle Internet Financial — Court records (no results) court_document Processed 📜 Receipt
2026 UNVERIFIED Research: Circle Internet Financial — USASpending contracts (no results) contract Processed 📜 Receipt
2026 UNVERIFIED Research: Circle Internet Financial — Lobbying disclosures (no results) government_disclosure Processed 📜 Receipt
2026-05-16 UNVERIFIED SEARCH_ERROR: Circle Internet Financial not found in sec_edgar claim_flag Processed 📜 Receipt