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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 a holder redeems
Redeem with the issuer in its window. Holders redeem into USDC in near real time, 24 hours a day, up to the instant-redemption limit, and arrange larger amounts separately. Settles in USDC.

In plain words on RIADeFi: Circle USYC.

This file replaced an earlier version 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 Superseded the same day: the control reading stopped at the token ABI and missed the RolesAuthority contract every transfer checks, which gates both wallets and can pause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. Earlier versions.

Subscribers see which of their clients hold this program and whether each household qualifies under these terms, and Ketju emails them when the file changes. $299 per firm per month, first 30 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
Next review
2027-03-23

Eligibility

Each answer quotes the issuer’s own words from the document named under it. Ketju reads each document again and records whether the words are still there. Where the documents say nothing, the row states that.

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; Circle does not offer USYC to individuals, trusts, or IRAs.

“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 that hold the entitlement role, which the contract checks on 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

Holders redeem into USDC in near real time up to the instant-redemption limit and may arrange more liquidity.

“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

The transfer agent holds the fund shares, and the tokens represent them on chain; the fund administrator keeps the share registry matched to the tokens.

“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

Circle can halt every USYC transaction at once through the entitlements contract while it resolves suspicious activity.

“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

FactAnswer
Who onboards the holderissuer
Voting rightsNone
Distributionsreinvested
SIPC coverage of the walletNo

Who controls it

Ketju read these powers from the deployed contracts and their verified source code: the token and every contract it checks on a transfer. A power listed here is something the issuer can do; it does not mean the issuer has used it.

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

Ketju read every current holder of each power from the chain on 2026-09-23. A single key is one private key, and whoever holds it acts alone. A multisig needs the stated number of signers. A timelock delays every action, so holders can see it before it takes effect.

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, 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, 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

Redemption

RouteSettlementSettles in
Redeem with the issuer in its windowHolders redeem into USDC in near real time, 24 hours a day, up to the instant-redemption limit, and arrange larger amounts separatelyUSDC

Daily checks

Every day Ketju reads each control function in the table above and the contracts the token checks on a transfer. Ketju compares the token’s on-chain supply with yesterday’s, and its market quote with yesterday’s quote, since a fund of this kind accrues a few basis points a day. Ketju also reads every document quoted above and reviews the file again if a quoted passage disappears from its document. Ketju counts a new, removed, or changed key as a change only when the chain’s own log shows the grant, revocation, or signer change since yesterday. If the log does not show it, Ketju updates the key list in this file and does nothing more. A change opens a review before any client action. Subscribers get an email that names each of their clients who hold the token, with the household result.

File history

Ketju has revised this file 3 times since filing it. Ketju keeps each earlier version as published, with the reason for the change.

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

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