Record retention

You’re required under your Definitive Agreement with Circle, and under applicable money services business (MSB) and state money transmitter regulations, to retain the following records. Failure to retain them is a regulatory violation.

Record type	What to retain	Minimum retention
Consent records	The user agreement version accepted, timestamp, user ID, IP address, and method of consent (checkbox, click).	5 years under New York money transmitter regulations (confirm for other jurisdictions)
Transaction receipts delivered	Proof that each receipt was generated and delivered: an event log with user ID, transaction ID, delivery method, and timestamp.	5 years
Customer communications	All material notices sent to end users (account approval, restriction, closure, returns).	5 years
Account statements	If you issue periodic statements, retain a copy of each statement sent.	5 years
Marketing materials	All marketing and promotional materials used to attract end users to the Digital Asset Accounts (DAA) product.	Duration of use plus 2 years
Know Your Customer (KYC) and Know Your Business (KYB) records	Identity verification documents and outcomes, governed separately by Circle’s reliance program.	5 years from account closure

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 don’t commingle them with non-DAA product records in ways that impede retrieval. If you operate European Economic Area (EEA) accounts, you’re also subject to record retention requirements under Markets in Crypto-Assets Regulation (MiCA) and the Autorité de contrôle prudentiel et de résolution (ACPR). Confirm specific periods with your legal counsel. For the full list of distributor obligations, see Compliance obligations.

Mint

Match

StableFX

Digital Asset Accounts

End User Onboarding