AMLBot Publishes ‘Stablecoin Freezes 2023–2025’ Report: $3.3B In USDT And $109M In USDC Restricted

In Brief

Between 2023 and 2025, Tether froze roughly $3.3 billion across 7,268 addresses using a proactive “freeze, burn, and reissue” approach, while Circle froze $109 million across 372 addresses only under legal or regulatory orders.

AMLBot, a platform specializing in cryptocurrency compliance and blockchain analytics, released a report titled “Stablecoin Freezes 2023–2025,” examining freezing activity for major stablecoins over this period and highlighting notable differences in approach and scale between Tether (USDT) and Circle (USDC).

The report analyzes freezes across Ethereum and TRON networks to track how these stablecoins have been utilized in investigative processes between 2023 and 2025. It details not only the frequency of freezes but also the reasons behind them, patterns observed, and their role in victim restitution, law enforcement coordination, and large-scale regulatory enforcement.

According to AMLBot’s updated Dune Dashboard for 2023–2025, Tether has blacklisted 7,268 addresses across Ethereum and TRON, freezing a total of $3.29 billion. Circle, by comparison, has blacklisted 372 addresses with $109 million frozen. Including TRON data further emphasizes the disparity: USDT freezes surpass USDC by roughly 30 times in both the number of addresses and the total asset value.

The underlying difference stems from contrasting operational approaches. Tether employs a proactive strategy, collaborating with law enforcement and blockchain intelligence providers, while Circle acts in response to formal judicial orders or regulatory requirements.

Tether’s enforcement footprint is extensive. Its freezing and reissuance processes have returned substantial sums to victims and supported law enforcement actions against fraud, terrorism, and human trafficking. Notably, in July 2024, USDT freezes exceeded $130 million, including $29.6 million on TRON linked to the Huione Group in Cambodia. Tether works with over 275 law enforcement agencies across 59 jurisdictions and often freezes tokens preemptively to prevent losses, even without court orders. Frozen tokens can be burned and replaced to facilitate victim restitution, with late 2025 showing spikes exceeding 25–30 million USDT destroyed. This centralized control, however, raises privacy and censorship concerns and has led to legal challenges, such as a lawsuit following the freezing of 44.7 million USDT at the request of the Bulgarian Police Department.

Circle, in contrast, follows a reactive, compliance-driven model. Its freezes, totaling $109 million across 372 addresses, are initiated only to satisfy legal obligations, such as court orders or sanctions. This results in fewer but larger batch actions, and the frozen assets remain static until formal authorization permits release. Circle does not implement a burn-and-reissue mechanism, maintaining a strictly legally anchored approach.

Comparing Stablecoin Freeze Policies: Tether’s Proactive Approach Vs. Circle’s Compliance-Driven Model

Tether and Circle implement stablecoin freezes using distinct approaches shaped by their respective policies and regulatory contexts. Tether issues USDT across multiple blockchains, including Ethereum, TRON, and Solana, with smart contracts that allow addresses to be blacklisted, funds to be burned, and new tokens to be issued for victim restitution or law enforcement purposes. Frozen addresses can sometimes be removed from the blacklist, and not all freezes lead to immediate burn or reissuance. Tether’s Terms of Service permit token freezes when required by law or at its discretion to protect users, and freezes are executed through a multi-signature wallet system, which can create brief delays exploited by illicit actors. Since 2017, such delays have contributed to approximately $78 million in losses, though Tether emphasizes the process is a safeguard for its $100 billion system. The company has frozen or reissued more than $2.7 billion in illicit funds and works with over 275 law enforcement agencies across 59 jurisdictions. While Tether occasionally freezes funds proactively to protect users, this centralized control has prompted legal challenges and raised concerns over privacy and censorship.

Circle, by contrast, governs USDC freezes with a reactive, compliance-driven model. Its smart contracts allow addresses to be blacklisted, preventing transfers without destroying the underlying tokens. Freezes are applied only to comply with legal orders, security incidents, or sanctions, and they can be reversed once the underlying issue is resolved. Circle maintains public reporting of frozen addresses and associated token amounts, with oversight from its accounting auditors, ensuring transparency. Operating primarily under US regulatory requirements, Circle’s freezes are legally anchored and less frequent, appearing as batch actions, unlike Tether’s continuous enforcement flow.

Together, these examples illustrate the tension in stablecoin management between proactive risk mitigation, user protection, and the principles of decentralization, highlighting how regulatory context, contract design, and company policy shape the application of freezes on blockchain assets.