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Digital Asset Accounts (DAA) operates under a B2B2C model in which Circle is the licensed money transmitter and you are responsible for surfacing compliance artifacts to your end users. Your obligations derive from your Definitive Agreement with Circle and from the money transmission regulations Circle operates under, including its money transmitter licenses and the New York BitLicense. Circle generates the required artifacts and returns them to you through the API and the corresponding webhook events. You render and deliver them.

Obligations at a glance

Receipts

Send a receipt to the end user when each transaction reaches its final state: an onramp deposit is credited, an offramp withdrawal settles, or an onchain transfer confirms. Circle returns the content fields on the API response and in the corresponding webhook event. You render the receipt and deliver it through your channel of choice (for example, email, in-app notification, or both). The following subsections map the fields you show on the receipt to their location in the API response. Every receipt must also include the required footer text.

Onramp receipts (wire deposit)

Send the receipt when the wire deposit transitions to complete. See Get an account deposit for the full response schema.

Offramp receipts (bank withdrawal)

Send the receipt when the bank withdrawal transitions to complete. Do not send a receipt for withdrawals that end in failed. Use a withdrawal return notice instead. See Get an account withdrawal for the full response schema.

Onchain receipts (deposit or send)

Send the receipt when the onchain transfer reaches a terminal state (confirmed onchain). Determine directionality from the source and destination fields. Inbound transfers (deposits into the account) have a blockchain source. Outbound transfers (sends from the account) have a blockchain destination. See Get an account transfer for the full response schema. Include the following text verbatim on every receipt. Do not modify it without Circle’s approval. The “User Agreement” and “Privacy” labels at the end must link to the URLs shown. Render the links in whatever format your channel supports (HTML anchor, email link, plain-text URL).

Disclosures

Disclosures are pre-transaction obligations, distinct from receipts. Present them to the end user before they can open an account or initiate a transaction, and capture affirmative consent.

Terms and conditions

Before you open an account or process a first transaction for an end user, present Circle’s Digital Asset Account User Agreement and capture explicit acceptance.
1

Present the user agreement

Display the user agreement as a link. Do not paraphrase or summarize the terms. The preferred consent wording is:
I have read, understand, and agree to the Digital Asset Account User Agreement.
2

Capture consent

Require an affirmative action such as a checkbox or an “I agree” button. Do not use pre-checked boxes.
3

Register acceptance with Circle

Call the Submit an application endpoint with:
  • endUserAgreesToTermsOfService: set to true
  • endUserIpAddress: the end user’s IP address at the time of consent
4

Log the consent event

Record the user ID, timestamp, user agreement version accepted, and IP address in your own records. Retain per the record retention requirements.
You must re-present the user agreement and re-collect acceptance whenever the version changes.

Per-transaction disclosures

Before executing any deposit, withdrawal, or transfer, display the following to the end user and require acknowledgment:
  • The estimated fee and net amount.
  • The estimated settlement time.
  • An irrevocability notice: wire and onchain transfers are generally final once initiated.

Account limits

Display account limits before the end user initiates a deposit or withdrawal so they cannot submit amounts that exceed their limit. Reversals caused by submissions that exceed the limit harm the user experience and create operational overhead.
  • Display Circle’s published per-transaction, daily, and monthly limits on your deposit and withdrawal screens.
  • Show the end user’s current balance before they initiate a withdrawal.
  • Block submission when the entered amount exceeds the applicable limit.

Regulated customer notices

Send lifecycle notices to end users when the account state changes in ways that materially affect them. These notices are triggered by account lifecycle events and are separate from transactional receipts. Some require advance notice and specific content under applicable law. Consult your legal counsel on advance notice requirements that apply in each jurisdiction for restriction and closure notices. New York and several other states impose statutory notice periods for adverse actions on financial accounts.

Record retention

You are required under your Definitive Agreement with Circle, and under applicable money services business (MSB) and state money transmitter regulations, to retain the following records. These are not optional. Failure to retain them is a regulatory violation that Circle might have to report. Circle has audit rights under the Definitive Agreement to inspect distributor record retention practices. Ensure records are accessible in 10 business days of a request. Store records securely and do not commingle them with non-DAA product records in ways that impede retrieval.

Account statements

Circle does not require periodic account statements for DAA. If you elect to issue them, or if applicable law requires them for certain account types or jurisdictions, include the following fields on each statement:
  • The statement period (start and end date).
  • The opening and closing balance.
  • Each transaction with its date, type (deposit, withdrawal, or transfer), amount, fee, net amount, and reference.
  • Dispute contact information and process.
  • Circle’s regulatory status and license information.

Implementation checklist

Before you enable live transactions for any end user, confirm the following:
  • Wire deposit receipt is rendered and delivered on deposit completion.
  • Bank withdrawal receipt is rendered and delivered on withdrawal completion.
  • Onchain transfer receipt is rendered and delivered on confirmation.
  • The Digital Asset Account User Agreement is surfaced and explicit consent is captured before account opening.
  • Pre-transaction disclosures (fee, settlement time, irrevocability) are shown before each transaction.
  • Account approval, restriction, closure, and withdrawal return notices are wired to the corresponding webhook events.
  • Consent, receipt delivery, and customer communication records are retained for the required period.

EEA compliance obligations

European Economic Area (EEA) accounts are issued under MiCA Article 60(4). Circle France SAS is the licensed entity and legal custodian for all EEA accounts, authorized by the AMF on April 20, 2026. For a full overview of the EEA regulatory framework, see EEA and MiCA. For the EEA onboarding flow, see Onboard EEA customers. EEA accounts require two contracting layers before activation. You contract with Circle France SAS (not Circle LLC) at the partner level. Each end user must accept the custody terms of Circle France SAS. Both layers must be in place before you activate an EEA account. As an EEA distributor, you must do the following:
  • Surface the EEA Terms: Present the EEA Terms to end users before account activation and capture click-through acceptance. This is in addition to the standard Digital Asset Account User Agreement.
  • Capture SCA consent: Present the SCA challenge before any SCA-sensitive action and obtain authenticated consent. See EEA API behavior for the full list of actions that require SCA.
  • Retain records: Follow the same requirements in Record retention for a minimum of 5 years. EEA partners are also subject to ACPR record retention requirements under MiCA. Confirm specific periods with your legal counsel.

No burn fees or ROLR

Digital Asset Accounts does not charge burn fees or apply ROLR programs for EEA accounts.