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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 delivering compliance artifacts to your end customers. Your obligations come 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.

Receipts

Send a receipt when each transaction reaches its final state: a deposit is credited, a withdrawal settles, or an onchain transfer confirms. For the full implementation reference, including required data elements, field mappings by transaction type, and required footer text, see Receipts and disclosures.

Disclosures

For implementation requirements, including the terms and conditions consent flow and per-transaction disclosure elements, see Receipts and disclosures.

Account limits

Display account limits before the end customer initiates a deposit or withdrawal so they can’t 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 limits and rolling 24-hour and 30-day limits on your deposit and withdrawal screens. See Limits and risk ratings.
  • Show the end customer’s current balance before they initiate a withdrawal.
  • Block submission when the entered amount exceeds the applicable limit.

Regulated customer notices

For the full list of notice triggers, required content, and timing requirements, see Regulated customer notices.

Record retention

For the full list of record types, retention periods, and audit requirements, see Record retention.

Account statements

If you elect to issue statements, 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 customer, 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 Markets in Crypto-Assets Regulation (MiCA) Article 60(4). Circle France SAS is the licensed entity and legal custodian for all EEA accounts, authorized by the Autorité des marchés financiers (AMF) on April 20, 2026. For a full overview of the EEA regulatory framework, see EEA and MiCA. For the EEA onboarding differences, see End customers in the EEA. EEA accounts require two contracting layers before activation:
  1. Your distributor agreement: If you’re an EEA-resident distributor, you sign it with Circle France SAS. Otherwise, your existing Circle LLC agreement covers EEA end customers, and you don’t need to sign a new one.
  2. The end customer’s custody terms: Each end customer accepts the custody terms of Circle France SAS.
If you serve EEA end customers, you must do the following:
  • Show the certifications: Before account activation, show EEA end customers the application’s active certifications, which include the DAA User Agreement EEA, and capture their acceptance. See Discover required certifications.
  • Capture SCA consent: Present the Strong Customer Authentication (SCA) challenge before any 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 distributors are also subject to Autorité de contrôle prudentiel et de résolution (ACPR) record retention requirements under MiCA. Confirm specific periods with your legal counsel.

No redemption fees or ROLR

Digital Asset Accounts doesn’t charge redemption fees or apply redeemer of last resort (ROLR) arrangements for EEA accounts.