Intermediate

Tether vs Circle: Different Freeze Policies

A detailed comparison of how the two largest stablecoin issuers approach blacklisting

USDT (Tether) and USDC (Circle) together represent over 90% of the stablecoin market. Both can freeze funds, but they approach blacklisting very differently. Understanding these differences helps you make informed decisions about which stablecoins to hold and how to manage your risk.

Market overview

Before diving into policies, let's understand the scale we're dealing with:

USDT (Tether) USDC (Circle)
Market Cap ~$110 billion ~$25 billion
Headquarters British Virgin Islands United States (Boston)
Chains Supported 15+ chains 10+ chains
Primary Use Global trading, emerging markets US/institutional, DeFi
Regulatory Status Offshore, less regulated US-regulated, licensed

Policy comparison

The two issuers have fundamentally different approaches to freezing funds:

Tether's Approach

Proactive
  • Freezes funds at law enforcement request
  • Sometimes freezes proactively during hacks
  • Works with global law enforcement
  • Has frozen 1,200+ addresses
  • Response time: hours to days
$

Circle's Approach

Conservative
  • Primarily freezes for OFAC sanctions
  • Requires formal legal process
  • Focused on US regulatory compliance
  • Has frozen ~300 addresses
  • Response time: typically slower
Key difference: Tether will often freeze funds based on direct law enforcement contact, while Circle typically requires formal legal process (subpoenas, court orders) before taking action—unless it's an OFAC sanctions matter.

Technical differences

Both use similar smart contract mechanisms, but with important differences:

Contract architecture

Tether (USDT) - TetherToken.sol
// Tether uses a simple blacklist mapping
mapping (address => bool) public isBlackListed;

function addBlackList(address _evilUser) public onlyOwner {
    isBlackListed[_evilUser] = true;
    AddedBlackList(_evilUser);
}

// Can destroy tokens at blacklisted address
function destroyBlackFunds(address _blackListedUser) public onlyOwner {
    require(isBlackListed[_blackListedUser]);
    uint dirtyFunds = balanceOf(_blackListedUser);
    balances[_blackListedUser] = 0;
    _totalSupply -= dirtyFunds;
    DestroyedBlackFunds(_blackListedUser, dirtyFunds);
}
Circle (USDC) - FiatTokenV2.sol
// Circle uses a "blacklister" role
address public blacklister;

function blacklist(address _account) external onlyBlacklister {
    _blacklist(_account);
}

function unBlacklist(address _account) external onlyBlacklister {
    _unBlacklist(_account);
}

// Note: Circle does NOT have a destroyBlackFunds function
// Frozen funds remain on the blockchain indefinitely

Key technical differences

Fund destruction

Tether Can destroy frozen funds
Circle Funds remain frozen, not destroyed

Multi-sig requirements

Tether Single owner key (varies by chain)
Circle Dedicated blacklister role

Unfreeze capability

Tether Rarely unfreezes addresses
Circle Has unBlacklist function, uses occasionally

Transparency and reporting

How open are these issuers about their blacklisting activities?

Tether

Transparency
Low-Medium
  • Announces major freezes via blog posts
  • No regular transparency reports on blacklisting
  • Blacklist events visible on-chain
  • Limited explanation for individual freezes

Circle

Transparency
Medium-High
  • Publishes transparency reports
  • Clear OFAC compliance documentation
  • US regulatory filings provide oversight
  • More predictable, policy-driven approach
On-chain visibility: Regardless of issuer transparency, all blacklist events are recorded on-chain. Services like Eagle Virtual monitor these events across all chains to provide real-time blacklist data.

Which is safer?

There's no simple answer—it depends on your situation and risk tolerance:

USDT may be better if you:

  • Operate outside the US regulatory sphere
  • Need maximum liquidity and trading pairs
  • Want faster response to hack recovery
  • Accept higher freeze risk for lower regulatory exposure

USDC may be better if you:

  • Operate primarily in US/EU markets
  • Need regulatory predictability
  • Want lower freeze frequency
  • Prefer formal legal process protections

Both can freeze you

Don't assume one stablecoin is "safe" from freezing. Both issuers have demonstrated willingness to blacklist addresses. The differences are in frequency and process, not capability.

Key takeaways

1
Tether freezes more frequently. Over 1,200 addresses vs ~300 for Circle, largely due to working with global law enforcement.
2
Circle requires more formal process. OFAC sanctions trigger automatic freezes, but other freezes typically need legal process.
3
Tether can destroy funds; Circle cannot. A significant technical difference with legal implications for fund recovery.
4
Diversification reduces risk. Holding multiple stablecoins across different issuers can limit exposure to any single freeze policy.