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[MONEY FLOW] CHAIN 4 HOPS 1 VANISH
// Money-flow chain

Circle USDC reserves → BlackRock fund fees → BlackRock political spend → SAB 121 reversal

Documented totalUSD —
As of2024-12-31
Confidence[INFERENTIAL]
// Source

USDC reserve assets are managed by BlackRock through the Circle Reserve Fund, generating management fees scaled to USDC outstanding supply. Those fees flow into BlackRock's general revenue, a portion of which funds BlackRock's federal lobbying and political spending — including on the 2024 SAB 121 repeal vote that lifted the SEC's bank-custody constraints on crypto assets and expanded the addressable market for both USDC reserves and BlackRock's own spot Bitcoin ETF (IBIT).

// Flow Diagram
undisclosedOther (see note)undisclosedFee / consulting paymentundisclosedOther (see note)undisclosedOther (see note)Circle IPOinsiders and loc…Circle InternetFinancialBlackRock⛔BlackRockfederal lobbying …SEC StaffAccounting Bullet…
// Hops
0
Other (see note) · secondary · 2025-06-05
Circle IPO insiders and lockup-eligible early shareholders (post-5 June 2025 NYSE listing) → Circle Internet Financial
USD — (Circle's June 2025 NYSE listing under the ticker CRCL turned founder, employee, and venture-investor stakes into liquid public equity. Holders of those stakes have a documented economic interest in any policy outcome (GENIUS Act licensure, SAB 121 repeal) that expands USDC float and therefore Circle's reserve-yield revenue.)
1
Fee / consulting payment · secondary · 2024-06-30
Circle Internet Financial → BlackRock
USD — (Circle pays BlackRock management fees scaled to assets in the Circle Reserve Fund; the precise fee schedule is not publicly itemised.)
⛔ Vanish point — Undisclosed beneficial owner
Reserve Fund is structured as a sub-advised vehicle; fee accrual to specific BlackRock business units, and the share of those fees attributable to USDC float versus other clients of the same fund family, is not disclosed.
2
Other (see note) · inferential · 2024-12-31
BlackRock → BlackRock federal lobbying and political spend
USD — (Portion of BlackRock general revenue allocated to federal lobbying and corporate PAC contributions. The share specifically attributable to crypto-policy positioning is not separately reported.)
3
Other (see note) · inferential · 2025-01-31
BlackRock federal lobbying and political spend → SEC Staff Accounting Bulletin No. 121
USD — (Industry advocacy for repeal culminates in the May 2024 passage of H.J.Res.109 (vetoed by President Biden) and the eventual SEC rescission of SAB 121 via SAB 122 in January 2025, removing the bank-custody constraint and expanding the addressable market for BlackRock's IBIT and Circle's reserve mandate.)
[PUBLIC COST ESTIMATE]
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.

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