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Eligibility file · Treasury fund

Circle USYC

What the client owns
Share of a Cayman Islands mutual fund holding short U.S. Treasury bills and reverse repurchase agreements. Issuer indirect: The token points at a record kept off chain; the transfer agent’s file governs and the chain is a mirror.
Who may hold it
Not offered to US persons. First purchase $100,000.
Who can freeze or claw back
Ethereum: can pause transfers, claw back, gate who may hold, mint, change the code. A single key can pause transfers.
Solana: can freeze a holder, pause transfers, claw back, gate who may hold, mint. A single key can pause transfers. An account only a program can sign for can change the code with no delay.
How it exits
Redeem with the issuer in its window. Into USDC in near real time, 24 hours a day, up to the instant-redemption limit; larger amounts by arrangement. Settles in USDC.

In plain words on RIADeFi: Circle USYC.

This file replaced an earlier record on 2026-09-23. Superseded the same day: the control reading stopped at the token ABI and missed the RolesAuthority contract every transfer checks, which gates both wallets and can pause all transfers. The file said no allowlist and no pause. Same claim model, terms, and exit. Superseded records.

Subscribers see which of their clients hold this program, each household’s answer against these terms, and an alert when the file changes. $49 per advisor per month, first 14 days free.

The verdict is on the memo: Circle USYC Not approved

Issuer
Hashnote International Short Duration Yield Fund Ltd. (Cayman); Circle International Bermuda Limited as issuer of the token
Registration
Regulation S, offshore
Official record
The fund’s transfer agent holds the shares; the fund administrator updates the share registry to match the tokens
Instruments
USYC
Chains
Ethereum, Solana
Reviewed
2026-09-23 · v1
Next review
2027-03-23

Who may buy, hold, transfer, and redeem

Each answer rests on the issuer’s own words, quoted from the document named under it. Ketju re-reads each document and records whether the words are still there. Where the documents say nothing, the row says so.

Who may hold it

Only entities that are not US Persons under Regulation S, and that pass Circle’s eligibility checks.

“USYC is available only to entities that are not U.S. Persons, as defined in Regulation S under the Securities Act of 1933. Eligibility restrictions apply.”

Circle developer docs — USYC overview · USYC overview, opening notice · words found 2026-09-23

First purchase minimum

$100,000.

“USYC offers yield-bearing exposure with a $100,000 minimum, allowing firms to stay agile while deploying capital efficiently.”

Circle: USYC product page, circle.com/usyc (Wayback Machine capture, July 25, 2026) · ”Institutional access without large upfront commitments” · words found 2026-09-23

Account types

Entities only. Individuals, trusts, and IRAs are not offered.

“Information about USYC is directed only to entities who are not US Persons, as defined in Regulation S under the Securities Act of 1933.”

Circle (Hashnote) USYC docs: Investor Onboarding · Eligibility, footnote 1 · words found 2026-09-23

Who it may be transferred to

Only between wallets of KYC’d entities holding the entitlement role. The contract checks every transfer.

“The wallets associated with KYC’ed entities receive a Role that entitles them to hold and transfer the token.”

Circle (Hashnote) USYC docs: Product Structuring · Entitlements · words found 2026-09-23

How a holder redeems

Into USDC in near real time, up to the instant-redemption limit. More liquidity can be arranged.

“USYC can be redeemed into USDC in near real time up to the instant-redemption capacity, with optional access to additional immediate liquidity.”

Circle: USYC product page, circle.com/usyc (Wayback Machine capture, July 25, 2026) · ”Near-instant redemptions” · words found 2026-09-23

Who keeps the official record

Fund shares held at the transfer agent. The tokens are digital twins; the fund administrator updates the share registry to match.

“Ownership in SDYF is represented as shares at the Transfer Agent, and whose digital twins are represented onchain as a Smart Contract token (ERC-20 specification).”

Circle (Hashnote) USYC docs: Product Structuring · Ledger · words found 2026-09-23

What the issuer says it can freeze or take back

The entitlements contract can halt every USYC transaction at once while suspicious activity is resolved.

“The Entitlements contract can also freeze all transactions involving USYC. As every type of action involving USYC verifies the Role of the sender, the Allowlist is positioned to revert all transactions.”

Circle (Hashnote) USYC docs: Product Structuring · Entitlements, System Halt · words found 2026-09-23

FactWhat the file records
Who onboards the holderissuer
Voting rightsNone
Distributionsreinvested
SIPC coverage of the walletNo

Who can change the record

Powers read from the deployed contracts and their verified source: the token and every contract it consults on transfer. A power recorded here is the issuer’s ability, not evidence it has been used.

ChainFreeze a holderPauseClaw backGate holdersChange the codeKeys held by
EthereumNoYesYesYesYesA single key can pause transfers.
SolanaYesYesYesYesNoA single key can pause transfers. An account only a program can sign for can change the code with no delay.

Who holds the keys

Every current holder of each power, read from the chain on 2026-09-23. A single key is one private key: whoever holds it acts alone. A multisig needs the stated number of signers. A timelock makes every action wait, so holders can see it coming.

ChainKeyWhat it can doHeld byAddress
EthereumOwnergrant and revoke these powersa single key0x13ff…2dd6
EthereumAuthority ownerpause transfers, decide who may hold, grant and revoke these powersa single key0x8fb0…2fc0
SolanaMint authoritymint new tokensan account only a program can sign forDZ7j2Y…i63y
SolanaFreeze authorityfreeze a holderan account only a program can sign forDZ7j2Y…i63y
SolanaPermanent delegateclaw back tokensan account only a program can sign forDZ7j2Y…i63y
SolanaPause authoritypause transfersa single keyEMMxae…vPZL
SolanaTransfer-hook authoritydecide who may hold, change the codean account only a program can sign forDZ7j2Y…i63y
Ethereum: 3 contract reads at block 26037153, 5 functions in verified source, 2026-09-23
Read from the chain
  • eip1967.implementation=0xbf0f2f3aad6b99893d80c550fbacec915545eb92
  • owner()=0x13ff8cabb86edf94a2df4f98773bda4005182dd6
  • authority()=0x902d906b8d988092213be799b18bd2cbd64f808c
Read from verified source
Solana: 4 contract reads at block 449565333, 0 functions in verified source, 2026-09-23
Read from the chain
  • mintAuthority=DZ7j2YLDq7847t2HtCWaDQUTpLJ4BinPGsY8w9Aai63y
  • freezeAuthority=DZ7j2YLDq7847t2HtCWaDQUTpLJ4BinPGsY8w9Aai63y
  • permanentDelegate=DZ7j2YLDq7847t2HtCWaDQUTpLJ4BinPGsY8w9Aai63y
  • defaultAccountState=frozen

Where it trades

VenueKind
Circle USYC portalissuer primary

How it exits

PathSettlementSettles in
Redeem with the issuer in its windowInto USDC in near real time, 24 hours a day, up to the instant-redemption limit; larger amounts by arrangementUSDC

What the monitor reads daily

Every control function in the table above and the contracts the token consults on transfer; the token’s on-chain supply against yesterday’s; and its market quote against yesterday’s quote, since a fund of this kind accrues a few basis points a day. Every document quoted above is re-read too, and a quote that leaves its document reopens the file. A key that appears, disappears, or changes shape counts as a change only when the chain’s own log shows the grant, revocation, or signer change between yesterday’s block and today’s; a difference the log does not show updates this file’s key list and nothing more. A change opens a review item in the governance queue and reopens the file before any client action. Subscribers get an email naming each of their clients who hold it, with the household result.

File history

Revised 3 times since it was filed. Each superseded copy is kept as published, with the reason it was replaced.

DateChange
2026-09-23Filed.
2026-09-23Revised. Superseded the same day: the control reading stopped at the token ABI and missed the RolesAuthority contract every transfer checks, which gates both wallets and can pause all transfers. The file said no allowlist and no pause. Same claim model, terms, and exit.
2026-09-23Revised. Superseded the same day: the file called the token the official record (issuer direct) while its own transfer-agent line said the administrator keeps the register. The documents reviewed do not settle which governs, so the claim model and the official record now say Not stated.
2026-09-23Revised. Superseded to quote the issuer’s terms: Circle’s documents say ownership is shares at the transfer agent and the administrator updates the register, which settles the open question; the claim model is now issuer indirect. Redemption is into USDC, around the clock, up to the instant limit.

Sources

The file is public. The subscription checks it against each of your households and watches it daily. $49 per advisor per month, first 14 days free. Start the trial.