--- title: "Paxos Review 2026: PAXG, PYUSD, USDP and USDG, What the Attestations Show, Who Can Redeem, and Who Holds the Keys" url: https://altstreet.investments/platforms/reviews/paxos kind: platform-review updated: 2026-10-31 description: "Paxos review 2026: PAXG, PYUSD, USDP and USDG from an OCC-chartered trust bank, with monthly KPMG attestations whose token counts match the chain exactly, new onboarding for businesses only, PAXG fees in transition, a 2025 New York consent order and token controls held at one address." publisher: AltStreet (https://altstreet.investments) license: Public factual pages may be read, quoted and cited with attribution and a link. Bulk redistribution is not permitted. --- # Paxos Review 2026: PAXG, PYUSD, USDP and USDG, What the Attestations Show, Who Can Redeem, and Who Holds the Keys Paxos issues four asset-backed tokens through an OCC-chartered national trust bank and two foreign affiliates: PAXG (one fine troy ounce of allocated London gold per token), PYUSD (the PayPal dollar), USDP and USDG (dollar stablecoins). KPMG attests to each token's backing every month, and on September 30, 2026 the on-chain supply matched those reports to the whole token. Direct minting and redemption are for verified customers: new onboarding is for business entities, existing individual accounts were moved to the Dashboard with withdrawal rights, EU residents have a direct USDG redemption route, and most individuals hold through exchanges and PayPal. A 2025 New York consent order found anti-money-laundering failures and imposed a $26.5 million penalty, and one on-chain address, whose signing arrangements are not public, holds the pause and freeze powers on all four Ethereum contracts. AltStreet score: 58.6 (B), scored October 30, 2026. Method: https://altstreet.investments/platforms | Field | Value | | --- | --- | | Platform | Paxos | | What it is | Regulated Token Issuer: Gold-Backed Token and Dollar Stablecoins from a National Trust Bank, with Crypto Brokerage and Custody Infrastructure for Enterprises | | Asset class | Tokenized allocated gold (PAXG) and fully reserved dollar stablecoins (PYUSD, USDP, USDG; BUSD in redemption only) | | Website | paxos.com | | Review first published | October 30, 2026 | | Last updated | October 31, 2026 | | AltStreet relationship | None: no affiliate, sponsorship or partnership | ## The short version What a holder owns here is a claim on Paxos Trust Company, N.A., a national trust bank, for a fixed quantity of an asset held for token holders: one fine troy ounce of allocated London Good Delivery gold per PAXG, or one dollar of cash, Treasury bills, repo and government money funds per PYUSD, USDP or USDG (USDG's issuers are Paxos's Singapore and Finnish affiliates). Three questions matter. First, what the attestations establish: KPMG reports monthly that each token is backed at or above par, and AltStreet's read of the Ethereum contracts at the September 30, 2026 report instant matched each report's token count to the whole token; the reserve side of each report rests on KPMG's examination. Second, who can redeem: the terms limit direct dealing to verified customers; new onboarding is for business entities since the retail wallet (May 2026) and itBit (August 2026) were retired, existing individual accounts were moved to the Dashboard with withdrawal rights, EU residents can redeem USDG directly, and whether a new US individual can open an account is not established; most individuals hold PAXG on exchanges and PYUSD through PayPal, so their liquidity is those venues'. Third, who controls the tokens and what the company's record is: one Ethereum address, with no contract code and signing arrangements that are not public, holds the pause and freeze powers on all four tokens and the admin role on USDP and PYUSD; every Solana mint shares one freeze authority and permanent delegate; and the company paid a $26.5 million penalty in August 2025 for anti-money-laundering and due-diligence failures, then converted to an OCC charter in December 2025 under nine enforceable conditions. - **435,306 oz** Allocated London Good Delivery gold held for PAXG holders on September 30, 2026, against 435,306 tokens outstanding, per KPMG. Vaulted with Brink's and ICBC Standard Bank; supplied by StoneX. Up from 370,506 tokens at the end of 2025 and 9,593 in January 2020. - **$5.98B** Reserves behind the four dollar tokens on September 30, 2026 (PYUSD $2,754.7M, USDG $3,168.4M, BUSD $34.5M, USDP $26.1M) against 5,973.1M tokens, per KPMG. Repo and Treasury bills dominate the US tokens; money funds and bills dominate USDG. - **Exact** AltStreet's read of Ethereum total supply at 21:00 UTC on September 30, 2026 matched the attested Ethereum token count for all four tokens to the whole token (PAXG 432,506; USDP 24,389,326; PYUSD 1,682,073,708; USDG 320,740,832). The check covers the token side of each report; the reserves rest on KPMG's examination. - **$26.5M** Civil penalty under the August 7, 2025 New York consent order, plus a $22 million compliance spending commitment through 2027. Findings: a deficient anti-money-laundering program before 2023, a breach of a 2020 letter agreement on Binance due diligence, and transaction monitoring failures. - **1 address** One Ethereum address with no contract code holds the pause and asset-protection (freeze and wipe) roles on PAXG, USDP, PYUSD and USDG, the supply-controller manager role on all four, and the default admin role on USDP and PYUSD, granted August 7 and 8, 2025; whether one key or a multi-party signing system stands behind it is not public. PAXG's and USDG's admin role sits with a one-day timelock. The logs show 371 addresses frozen across the four tokens, mostly in batches, and a 300 trillion PYUSD mint on October 15, 2025 reversed 22 minutes later. - **0.125% to 0.500%** PAXG redemption fee bands since September 1, 2026, on each account's rolling 30-day net redemptions. Creation fees are waived through January 1, 2027 (then 1.000% on 2 to 25 oz, down to 0.125% above 800 oz). No storage fee 'at this time'; the terms reserve one by dilution. Data note: Supply and reserve figures are as printed in the KPMG attestation reports as of September 30, 2026, 5:00 PM Eastern, and as read from the Ethereum and Solana contracts by AltStreet at the 21:00 UTC attestation instant on September 30, at 23:59 UTC month ends, and on October 30, 2026. The attestations are examinations of management's assertion at an instant, not audits of Paxos. Fees are as published on paxos.com and support.paxos.com on October 30, 2026; institutional terms are set in pricing supplements that are not public. PAXG dollar values are quoted only from CoinGecko and labeled as market data; Paxos publishes no gold price. ## Key figures | Figure | What it is | Context | | --- | --- | --- | | Exact | The token-count side of each report is independently checkable against the chain, and it checks. | AltStreet's read of Ethereum totalSupply at 21:00 UTC on September 30, 2026 matched the attested Ethereum token count for PAXG, USDP, PYUSD and USDG to the whole token. PAXG 432,506; USDP 24,389,326; PYUSD 1,682,073,708; USDG 320,740,832 on Ethereum; Solana cannot be read historically. The reserve side rests on KPMG's examination. | | $26.5M | The reserves were never found short; the company's compliance function was. | Civil penalty under the 2025 New York consent order, with a $22 million minimum compliance commitment for 2025 to 2027. Findings: deficient AML program before 2023, breach of the 2020 Binance letter agreement, transaction monitoring failures; cooperation credited. | | 1 address | Address with no contract code holding the pause and freeze roles on all four Ethereum tokens and the admin role on USDP and PYUSD. | 0x3Af3e85f4f97De7AD0f000B724Fb77fE5ffc024B; roles granted August 7 and 8, 2025, per RoleGranted and RoleRevoked logs read October 30, 2026; signing arrangements not public. | | 0 fee | To mint or redeem PYUSD, USDP or USDG with Paxos as a verified customer. | Stablecoin terms 2.8.2.1; $2 monthly dormancy after twelve idle months; wire fees apply. | ## Verdict KPMG examines each token's backing monthly (twice monthly for the dollar tokens), prints supply by chain and reserves by instrument, and the on-chain token counts matched the September 30, 2026 reports exactly; the issuer is now a national trust bank. Set against that are a 2025 consent order describing systemic anti-money-laundering failures that the OCC charter is conditioned on fixing, new onboarding limited to business entities, PAXG fees in transition, and token controls concentrated at one address whose signing arrangements are not public. **Best for** - Businesses that can onboard directly and want par redemption with no fee from a bank-chartered issuer. - Holders who value third-party monthly attestations that can be checked against the chain. **Look elsewhere if** - You expect to open a new individual account with Paxos. - You need yield from the token itself. - You need an issuer with an audited public balance sheet and no recent enforcement history. **Strengths** - Monthly KPMG attestations per token with per-chain supply and instrument-level reserves; AltStreet's chain read matched the token counts to the whole token. - National trust bank issuer (OCC Charter 25379) with segregated custody; Singapore and Finnish licensed issuers for USDG. - Complete published terms and a full PAXG fee schedule; no storage fee today; no fee to mint or redeem the dollar tokens. - Operational record through the BUSD and USDL wind-downs: redemptions at par on published dates. **Limitations** - August 2025 consent order: $26.5 million penalty for AML, due diligence and monitoring failures, with remediation running through 2027 under OCC conditions. - New onboarding for business entities only since May and August 2026; a new US individual's eligibility not established; PAXG unavailable in the EU. - Pause, freeze and admin powers held at one Ethereum address and one Solana authority, with signing arrangements not public; unverified proxy admin contracts. - Undated marketing figures; parent company unnamed on the site; banks anonymized; no issuer financials. ## Who it fits | Investor | Fit | Why | | --- | --- | --- | | Payment companies, exchanges and treasuries that can onboard as direct customers | well-suited | | | Individuals who want gold exposure on-chain and accept exchange liquidity | neutral | | | Holders who need yield from the token itself | poor-fit | | | Holders who need deposit insurance or a bearer asset outside issuer control | poor-fit | | ## Questions **Is Paxos legit?** Paxos Trust Company, N.A. is a national trust bank chartered by the OCC since December 12, 2025 (a New York trust company from 2015 to 2025), and KPMG attests every month that each of its tokens is backed at or above par; AltStreet's own chain reads matched the token counts in those reports exactly on September 30, 2026. The company paid a $26.5 million penalty to New York in August 2025 for anti-money-laundering and due-diligence failures and is remediating under OCC conditions through 2027. AltStreet located no SEC or FINRA action naming it. **Is PAXG really backed by gold?** KPMG's report as of September 30, 2026 states 435,306 PAXG tokens outstanding against 435,306 fine troy ounces of London Good Delivery gold held with Brink's and ICBC Standard Bank. The terms describe each token as a pro rata beneficial interest in allocated bars, and holders in self-custody can look up their bar serial numbers on paxg.com. The reports do not list the bars or the vault split, and Paxos's annual physical count by Bureau Veritas is described by Paxos as not an attestation of ownership or valuation. **Can I buy PAXG or PYUSD directly from Paxos?** It depends on which of three questions you are asking. A new account: Dashboard onboarding asks for organizational documents, the retail wallet was retired on May 29, 2026 and itBit on August 9, 2026, and whether a new US individual can open an account is not established. An existing individual account: funded retail accounts were moved to the Dashboard, where holders can withdraw crypto or fiat. Token-specific rights: verified customers redeem at par or at the gold quote, and EU residents can redeem USDG directly through a form. Otherwise Paxos points individuals to the exchanges listed on paxg.com for PAXG and to PayPal and Venmo for PYUSD; PAXG is described as currently unavailable in the EU. **What does it cost to hold and redeem PAXG?** No storage fee at this time. Creation fees are waived through January 1, 2027 (then 1.000% on 2 to 25 oz, down to 0.125% above 800 oz). Redemption to dollars costs 0.125% on the first $2 million of 30-day net redemptions, rising to 0.500% above $20 million; in-kind conversion adds 0.05%; wires cost $20 or $30; a $2 monthly charge applies after twelve idle months. The terms reserve a storage fee charged by diluting all holders on thirty days' notice. Exchange fees and spreads are separate. **Can Paxos freeze my tokens?** Yes. The terms allow Paxos to freeze, seize or forfeit tokens on legal process or in its sole discretion. The Ethereum logs show 371 distinct addresses frozen across the four tokens since deployment, mostly in list-wide batches, and thirteen wipes of frozen balances, including the FTX-linked PAXG addresses frozen in November 2022 and wiped that December. On Ethereum one address, whose signing arrangements are not public, holds the pause and freeze roles on all four tokens; on Solana one authority is freeze authority and permanent delegate for all four mints; on Stellar the PYUSD issuer has revocable authorization and clawback enabled. **Does PYUSD or USDG pay interest?** Not from Paxos. The terms say the dollar tokens are not designed to create returns for holders, and Paxos keeps the reserve earnings, sharing them with PayPal (PYUSD) and with Global Dollar Network partners (USDG). PayPal pays its own variable reward on PYUSD balances held in PayPal, 4% on October 30, 2026, which it says is not a deposit and may change. **What happened with BUSD and the SEC?** New York ordered Paxos to stop minting BUSD on February 13, 2023 over its oversight of Binance, and the SEC staff issued a Wells notice the same month alleging BUSD was an unregistered security. Paxos redeemed $7.9 billion in 32 days and has wound down more than $16 billion; 34.4 million BUSD remained on September 30, 2026, redeemable at par. Paxos says the SEC sent a termination notice on July 9, 2024. The Binance oversight failures became part of the August 2025 New York consent order. ## Evidence appendix Platform website captured October 30, 2026. Fifty paxos.com pages including every terms page and the five transparency pages; 71 support articles; developer docs; 69 releases and blog posts; paxg.com, globaldollar.com and PayPal's PYUSD page and terms; 29 Wayback snapshots (2017 to 2026); KPMG attestation PDFs for all five tokens (September 30, 2026 and earlier dates to 2020); DFS, OCC, SEC, MAS, FIN-FSA, ESMA and Connecticut records; Kabompo Holdings' six Form Ds; the Sizemore v. Zhao order on govinfo; Ethereum and Solana reads via public RPC with sourcify-verified source; AltStreet's enforcement tables. **Highlights** - PAXG attestation, September 30, 2026: 'Total PAXG redeemable tokens outstanding 435,306' against 'Total redemption assets in fine troy ounces of gold 435,306'; gold 'stored with Brink's Global Services Ltd. and Industrial and Commercial Bank of China Ltd (ICBC) Standard Bank'. - PYUSD attestation footnote: 'Paxos is entitled to and may withdraw all net returns earned on assets to the extent it exceeds the total outstanding redeemable token supply'. - DFS consent order, paragraph 26: 'prior to 2023, Paxos's BSA/AML compliance function was deficient ... Paxos onboarded customers with limited insight into their true identities, the legitimacy of their businesses, or the sources of their funds.' - OCC Conditional Approval No. 1358, condition 4: 'The Bank must obtain a written determination of no objection from the OCC before the Bank offers, markets, issues, or otherwise makes available Global Dollar (USDG) within the Multi-Jurisdictional Stablecoin Issuance Platform'. - PAXG terms 15.2: 'Paxos may charge storage fees to all token holders by issuing to Paxos new PAXG tokens, thereby diluting the value of existing PAXG tokens'. - Support, Wallet UI Deprecation FAQ: the Dashboard 'is designed for enterprise customers and does not provide a retail trading interface'. **Primary source pages** - paxos.com/paxg-transparency, /usdp-transparency, /pyusd-transparency, /busd-transparency, /usdg-transparency: KPMG reports as of September 30, 2026 (PDFs linked from the page modules). - paxos.com/terms-and-conditions/pax-gold-terms-conditions (Last Modified December 12, 2025) and the US Dollar-Backed Stablecoin Terms and Conditions (Last Modified June 30, 2026). - support.paxos.com 'PAX Gold Fees' (updated about September 2026), 'USD Fiat Deposit & Withdrawal Fees', 'Wallet UI Deprecation FAQ'. - DFS consent order, In the Matter of Paxos Trust Company, LLC, August 7, 2025, and DFS press release of the same date. - OCC Conditional Approval No. 1358, December 12, 2025, and the OCC national trust bank list as of September 30, 2026. - SEC Release No. 34-105562 (May 27, 2026), Release No. 34-103624 (August 1, 2025) and the October 28, 2019 no-action letter. - Kabompo Holdings, Ltd. Form D/A filed July 29, 2021 (CIK 1587702). - Connecticut Department of Banking consent order, July 23, 2020, and Bulletin 2945. - Ethereum contracts 0x45804880De22913dAFE09f4980848ECE6EcbAf78 (PAXG), 0x8E870D67F660D95d5be530380D0eC0bd388289E1 (USDP), 0x6c3ea9036406852006290770BEdFcAbA0e23A0e8 (PYUSD), 0xe343167631d89B6Ffc58B88d6b7fB0228795491D (USDG), read at block 26092843 (September 30, 2026, 20:59:59 UTC) and block 26308149 (October 30, 2026). ## Related - Full review (HTML): https://altstreet.investments/platforms/reviews/paxos - Every platform review: https://altstreet.investments/platforms/reviews - Methodology and scoring: https://altstreet.investments/platforms - Category hub: https://altstreet.investments/categories/tokenized-rwa --- Source page: https://altstreet.investments/platforms/reviews/paxos Machine index: https://altstreet.investments/llms.txt AltStreet reads what platforms, funds and issuers file with the SEC and what they tell investors, and publishes the difference. Figures are as filed or as captured on the date stated; nothing here is investment advice.