First Digital USD (FDUSD) Review
Bankruptcy-segregated reserves in a Hong Kong trust
of 10
FDUSD reserves are custodied by First Digital Trust Limited, a Hong Kong registered trust company, fully segregated from the trust's own assets so they survive its insolvency. The issuing entity is BVI-registered, and attestations are monthly.
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Issuer
FD121 (BVI) Limited
Custodian
First Digital Trust Limited, Hong Kong
Segregation
Reserves segregated to isolate the trust company's bankruptcy
Backing
Cash, very short-dated US T-bills, overnight reverse repos
Attestation
Monthly, independent
Scores
Each criterion carries equal weight. The overall score is the average of these 5 scores — (8.0 + 6.0 + 6.0 + 9.0 + 8.0) ÷ 5 = 7.4.
Pros
- Reserve assets fully segregated from the trust company's own assets to isolate its bankruptcy
- Custodian is a registered trust company under Hong Kong's Trustee Ordinance
- Reserves in cash, very short-dated US T-bills and overnight reverse repos
- Independent attestation reports published monthly
Cons
- The issuing entity is BVI-registered, a lighter regime than a US or Singapore charter
- No named prudential regulator supervises the issuer itself, only the custodian's trust licence
- Retail redemption terms are not set out on the pages we checked
- The attesting firm is not named
Segregation done properly
Reserve assets are custodied by First Digital Trust Limited, a licensed Trust or Company Service Provider and registered trust company under Hong Kong's Trustee Ordinance, with assets fully segregated from the trust company's own so that its insolvency does not reach them. That is the specific legal protection this criterion exists to identify, and FDUSD documents it clearly.
The issuer sits offshore
The issuing entity is BVI-registered. Segregated custody in Hong Kong is a real protection, but it is not the same as the issuer itself being supervised by a named prudential regulator, which is what NYDFS, the OCC and MAS provide elsewhere in this list.
Reserve composition
Cash, a basket of very short-dated US Treasury bills and overnight reverse repos — short duration by design, though the attesting firm is not named.
Who issues FDUSD?
FDUSD is issued by FD121 (BVI) Limited, trading as First Digital Labs, a subsidiary of the First Digital Group based in Asia. The reserves are held not by the issuer but by First Digital Trust Limited, a registered trust company in Hong Kong, and segregated so they survive the trust's insolvency. That split — a BVI-registered issuer over a Hong Kong custodian — is exactly the structure the review weighs: strong segregation, but a lighter issuer-level regime than a US or Singapore charter.
How it compares
Gemini Dollar (GUSD)
Named auditor, named regulator, named custodians
Ripple USD (RLUSD)
Dual regulatory approval with a named custodian
USD Coin (USDC)
Instrument-level reserve disclosure
Pax Dollar (USDP)
Cash-only reserves with unconditional redemption
PayPal USD (PYUSD)
Regulated issuer behind a consumer brand
Global Dollar (USDG)
Supervised in Singapore and under MiCA in Europe
Tether (USDT)
The largest supply, the thinnest disclosure cadence
Sky USDS
Crypto-collateralised with public collateral data
Ethena USDe
Synthetic dollar, and says so
Sources
Scored from published primary sources rather than hands-on use. Every figure above comes from one of the pages below, on the date shown. Manufacturers change prices and specifications without notice — if something here no longer matches the source, tell us and we will correct it.
Frequently asked questions
Who holds FDUSD reserves?
Reserves are custodied by First Digital Trust Limited, a registered trust company in Hong Kong, with assets fully segregated from the trust company's own assets.
Who issues FDUSD?
First Digital Labs is the brand of FD121 (BVI) Limited, a BVI-registered subsidiary of the First Digital Group.
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