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.
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What the data actually shows - TL;DR
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.
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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.
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.
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.
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.
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.
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.
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.
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.
Quick Verdict
Is this platform right for you?
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.
Avoid 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.
Top 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.
Key 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.
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Quick Answers
What most investors want to know first
The highest-signal facts first: minimums, liquidity reality, K-1 timing, and whether distributions are actually part of the experience.
Liquidity
PAXG trades around the clock on centralized and decentralized venues; its price against spot gold is set by those markets, and Paxos publishes neither a price nor a reference spread. The dollar tokens trade at or near $1.00 against Paxos's par redemption promise to direct customers.
K-1 Timing
Not applicable; no partnership reporting.
Distributions
Not applicable.
Overview
Platform Overview
A concise read on what the platform is, how the structure works, and where the practical friction shows up for real investors.
Paxos Trust Company began as itBit Trust Company, LLC, which received a New York limited purpose trust charter in May 2015 to run the itBit bitcoin exchange; the company says it was founded in 2012 (one page says 2013) and rebranded to Paxos in 2016. New York authorized the Paxos Standard dollar token (PAX, now USDP) in September 2018 and PAX Gold and the Binance-branded BUSD in September 2019. PYUSD launched for PayPal in August 2023 and USDG, issued from Singapore and later Finland, in November 2024.
On December 12, 2025 the trust company converted to Paxos Trust Company, National Association, a national trust bank under the OCC (Charter No. 25379) that takes no deposits and is not FDIC insured. Its ultimate parent is Kabompo Holdings, Ltd., a Cayman Islands company whose Form Ds report $301.6 million sold in its 2021 round to 20 investors; Paxos's releases describe a $300 million Series D at a $2.4 billion valuation and more than $540 million raised in all. The business today has two lines: stablecoin issuance (minting and redeeming PYUSD, USDP and USDG for business customers at par with no fee, and PAXG against gold) and crypto brokerage and custody for enterprises (PayPal, Venmo, Interactive Brokers, Nubank, Mercado Pago and others named on its pages).
The itBit exchange was retired on August 9, 2026 and the retail wallet interface on May 29, 2026; new Dashboard onboarding is for business entities, and existing individual accounts were moved to the Dashboard with the right to withdraw crypto or fiat. Affiliates hold a Singapore major payment institution license (Paxos Global and Paxos Digital Singapore), a Finnish electronic money institution authorization (Paxos Issuance Europe Oy, the former Membrane Finance) and, since May 2026, a temporary SEC clearing agency registration (Paxos Securities Settlement Company).
New York authorized Paxos Standard (PAX) in September 2018 and PAX Gold and BUSD in September 2019; the SEC staff gave Paxos a no-action letter for a securities settlement service in October 2019. Series C ($142 million) closed in December 2020 and Series D ($300 million at a $2.4 billion valuation) in April 2021, with Bank of America, Coinbase Ventures, Founders Fund and FTX added that July; the OCC granted preliminary conditional approval for a de novo national trust bank the same month. Paxos Global received a Singapore major payment institution license effective October 2022.
In November 2022 Paxos froze 11,184 PAXG at federal law enforcement's direction. On February 13, 2023 New York ordered it to stop minting BUSD and the SEC staff issued a Wells notice; Paxos redeemed $7.9 billion of BUSD in 32 days. PYUSD launched for PayPal in August 2023; Paxos received Abu Dhabi in-principle approvals in November 2023 and launched the yield-bearing USDL from there in June 2024; the SEC investigation ended in July 2024; USDG launched from Singapore in November 2024.
In 2025 Paxos completed the Membrane Finance acquisition (February), was named a defendant alongside Binance in Sizemore v. Zhao, entered the New York consent order (August 7), applied for the OCC conversion (August 12), wound down USDL (October to December), acquired Fordefi (November) and converted to a national trust bank (December 12). In 2026 USDG's attestation moved to KPMG Singapore (February), the retail wallet was retired (May 29), the SEC granted PSSC temporary clearing agency registration (May 27), PAXG launched on Solana (June), itBit was retired (August 9) and the PAXG redemption fee schedule changed (September 1).
PAXG reserves (Sep 30, 2026, KPMG)
435,306 tokens against 435,306 fine troy ounces of allocated London Good Delivery gold; Brink's and ICBC Standard Bank vaults; StoneX supplier; surplus nil.
PYUSD reserves
2,747.6M tokens against $2,754.7M: cash $100.4M (uninsured $100.2M, $50M captive excess cover), overnight Treasury repo $2,155.3M, Treasury bill $499.0M.
USDG reserves
3,165.0M tokens against $3,168.4M (0.11% over par): cash $78.1M in MAS- and CSSF-supervised accounts, government money funds $1,678.0M, Treasury bills $1,412.3M; $16.1M held in the EU.
USDP and BUSD reserves
USDP 26.1M tokens against $26.1M (cash $14.2M, repo $11.9M); BUSD 34.4M against $34.5M (cash $0.9M, repo $33.6M), redemption only.
New accounts
Dashboard onboarding asks for organizational documents; the retail wallet was retired May 29, 2026 and itBit August 9, 2026; a new US individual's eligibility is not established.
Existing individual accounts
Funded retail accounts were moved to the Dashboard, where holders can withdraw crypto to a self-custodial wallet or fiat to a linked bank account after a possible KYC refresh.
Token-specific redemption
Verified customers redeem at par (dollar tokens) or at the gold quote (PAXG); EU residents have a direct USDG redemption form; PAXG is 'currently unavailable in the EU'. Most individuals hold PAXG on sixteen listed exchanges and PYUSD through PayPal and Venmo at $1.00.
Fees
Dollar tokens: zero to mint and redeem; $2 monthly dormancy after twelve months idle. PAXG: creation waived to January 1, 2027 (then 0.02 PAXG flat under 2 oz, 1.000% to 0.125% by size); redemption 0.125% to 0.500% on 30-day net; in-kind 0.05%; storage none at this time; wire $20 or $30.
Chains
PAXG: Ethereum, Solana, Robinhood Chain, Base. PYUSD: Ethereum, Solana, Arbitrum One, Stellar, Polygon, Ink, X Layer, Stable. USDG: Ethereum, Solana, Ink, X Layer, Arbitrum One, Robinhood Chain, Mantle. USDP and BUSD: Ethereum (USDP also Solana).
Regulators
OCC (national trust bank, Charter 25379, since December 12, 2025; New York trust charter 2015 to 2025); MAS (two major payment institutions); FIN-FSA (electronic money institution); SEC (PSSC temporary clearing agency registration, May 2026). Attestations: KPMG LLP (Withum before February 2025; Enrome before February 2026 for USDG).
Owner and funding
Kabompo Holdings, Ltd. (Cayman Islands) is the ultimate parent per the OCC letter; its Form Ds report $301.6M sold in 2021 to 20 investors. Paxos releases: more than $540M raised; $2.4B valuation in April 2021. CEO and co-founder Charles Cascarilla; six directors named.
Visual Summary
Paxos against the tokenized asset issuers AltStreet covers
What the holder's claim is and who can deal directly with the issuer, from each issuer's own documents as recorded in AltStreet's reviews.
Paxos (PAXG, PYUSD, USDP, USDG)
What the holder holds
A redemption claim on a national trust bank (or its Singapore and Finnish affiliates) for one ounce of allocated gold or one dollar of reserves
Who deals directly
Verified customers; new onboarding for businesses; most individuals via exchanges and PayPal
Franklin Benji (FOBXX)
What the holder holds
A share of an SEC-registered government money market fund recorded on-chain
Who deals directly
US investors from $20
Superstate (USTB, USCC)
What the holder holds
Shares of private funds recorded as tokens by a registered transfer agent
Who deals directly
Qualified purchasers, $100,000 minimum
YLDS (Figure)
What the holder holds
An SEC-registered interest-bearing certificate
Who deals directly
US and eligible investors through Figure
Investor Operations
The practical questions investors actually care about: when tax documents arrive, how cash distributions work, and whether capital can be exited before the underlying asset is sold.
Tax Documents
K-1 Timing
What to expect
Not applicable; no partnership reporting.
Cash Flow
Distributions
Frequency
None. The dollar tokens pay no yield to holders; PAXG pays nothing and tracks gold.
Timing
Not applicable.
Consistency
Reserve returns accrue to Paxos and its partners; PayPal's PYUSD reward (4% as of October 30, 2026) is variable and PayPal's alone.
Liquidity
Exit Reality
Holding period
None. Redemption at par (dollar tokens) or at the gold quote (PAXG) for verified customers; exchange or PayPal liquidity for individuals.
Exit options
- Redeem with Paxos as a verified customer (dollars by wire); existing individual Dashboard accounts can withdraw crypto or fiat; EU residents can redeem USDG through the form.
- Sell PAXG on one of the sixteen exchanges listed on paxg.com, or convert PYUSD to dollars in PayPal or Venmo at $1.00.
- For PAXG, redeem in kind into unallocated gold or into allocated bars from 430 tokens.
Secondary market
PAXG trades around the clock on centralized and decentralized venues; its price against spot gold is set by those markets, and Paxos publishes neither a price nor a reference spread. The dollar tokens trade at or near $1.00 against Paxos's par redemption promise to direct customers.
Investment Structures
PAXG (Pax Gold)
One fine troy ounce of London Good Delivery gold per token, held by Paxos Trust Company on a segregated basis in LBMA-approved vaults (Brink's Global Services and ICBC Standard Bank; gold bought from StoneX) and allocated to bars that holders can look up by wallet address on paxg.com. 435,306 tokens and ounces on September 30, 2026 (370,506 at the end of 2025); on Ethereum, Solana (since June 2026), Robinhood Chain and Base. Creation and redemption with Paxos for verified customers during London gold market hours against a five-second streaming quote from StoneX, rounded down to a hundredth of an ounce; redemption to dollars, to unallocated gold, or to allocated bars from 430 PAXG.
Fees as in the table above; no storage fee at this time; on-chain transfers carry no Paxos fee since the June 2026 implementation. Minimum trade 0.01 oz on the page. The terms call the token 'akin to a warehouse receipt' and say the gold does not form part of Paxos's estate in an insolvency.
PYUSD (PayPal USD)
A dollar stablecoin issued by Paxos Trust Company, N.A. and distributed by PayPal and Venmo, which buy and sell it at $1.00 and are obliged by Paxos to trade it at that price. 2,747.6 million tokens and $2,754.7 million of reserves on September 30, 2026 (3,604.6 million at the end of 2025), on eight networks; reserves in cash at Federal Reserve-regulated institutions, overnight Treasury repo and Treasury bills (PayPal's terms exclude money market funds). Zero fee to mint or redeem with Paxos for verified customers and zero to convert with PayPal; PayPal charges 1.5% on one-step transfers to external wallets and pays a variable reward it says is not a deposit.
Reserve earnings go to Paxos and may be shared with PayPal. Not available to PayPal customers in Hawaii.
USDP (Pax Dollar)
Paxos's own dollar stablecoin since September 2018 (as Paxos Standard, PAX). 26.1 million tokens and $26.1 million of reserves on September 30, 2026, down from 109.7 million on Ethereum in October 2024; Ethereum and Solana. Same terms as PYUSD: redemption at par, no redemption fee, reserves in FDIC-insured bank cash, Treasury debt including repo and government money funds. Paxos no longer publishes the unaudited monthly reserve self-reports for USDP; the KPMG attestations continue.
USDG (Global Dollar)
A dollar stablecoin issued by Paxos Digital Singapore Pte. Ltd. (a Monetary Authority of Singapore major payment institution) and Paxos Issuance Europe Oy (a Finnish electronic money institution with a MiCA white paper), launched November 2024. 3,165.0 million tokens and $3,168.4 million of reserves on September 30, 2026 (0.11% over par; $16.1 million held in the EU), mostly on X Layer, Robinhood Chain and Solana; reserves in segregated cash under MAS and CSSF supervision, government money funds and Treasury bills under three months.
Zero fee to mint or redeem for institutions; EU residents can redeem through a form or partners. Global Dollar Network partners receive 'up to 100% of the returns generated by assets backing USDG held on your platform'. The OCC requires its no-objection before the US bank offers USDG within the multi-jurisdictional platform. The attestation is by KPMG LLP Singapore under Singapore standards and is addressed to the MAS submission.
BUSD (Binance USD), redemption only
Issued from September 2019 under a Binance brand; minting stopped on February 21, 2023 at New York's direction. 34.4 million tokens and $34.5 million of reserves on September 30, 2026, down from 15.9 billion on February 13, 2023; Ethereum only, redeemable at par by onboarded customers or convertible to USDP. Binance-Peg BUSD on other chains was never a Paxos token.
Lift Dollar (USDL), wound down
A yield-bearing, daily rebasing stablecoin issued by Paxos International under Abu Dhabi's FSRA from June 2024 (Ethereum and Arbitrum). Minting ended October 8, 2025; rebasing and redemptions ended December 8, 2025; balances above $1 were converted to USDG and balances under $1 'will not be recouped'. No transparency page remains.
Risk
Risk Structure
This is where the marketplace pitch gives way to the actual operating reality: delayed exits, limited disclosure, fee drag, and path-dependent outcomes.
The claim
A redemption claim on the issuer under its terms, not a deposit (no FDIC or SIPC protection) and not a security the issuer registers; Paxos says the assets are segregated and bankruptcy remote under its terms and federal banking law.
Direct access
New onboarding for business entities; existing individual accounts moved to the Dashboard with withdrawal rights; EU residents can redeem USDG directly; most individuals exit through exchanges and PayPal under those venues' terms.
Pause
PAUSE_ROLE on all four Ethereum tokens: one address with no contract code (0x3Af3e85f...024B). Used once, at PAXG's deployment in 2019.
Freeze and wipe
ASSET_PROTECTION_ROLE on all four Ethereum tokens: the same address. 371 addresses frozen since deployment, 13 wipes. On Solana one freeze authority and permanent delegate for all four mints; on Stellar the PYUSD issuer has revocable authorization and clawback enabled.
Admin role
USDP and PYUSD: the same address, with a three-hour delay on transferring the role. PAXG and USDG: a timelock contract with a one-day minimum delay.
Upgrades
PAXG, USDP, PYUSD: zOS proxies whose admin contracts hold the upgrade power and are not source-verified; no delay established. USDG: UUPS, upgrade function on the implementation gated by the default admin role, so the one-day timelock applies.
Minting
Delegated to SupplyControl contracts with per-controller daily rate limits (largest PYUSD controller 1 billion capacity, 24 billion a day refill); manager role on all four held by the same address. One erroneous 300 trillion PYUSD mint on October 15, 2025, reversed in 22 minutes.
Compliance record
A 2025 New York consent order ($26.5 million; AML program, transaction monitoring and letter-agreement violations) with remediation spending and OCC conditions running through 2027; a 2020 Connecticut order ($10,000) for unlicensed money transmission.
Fee terms
Published schedule with a waiver ending January 1, 2027, a redemption schedule changed September 1, 2026, a reserved dilution storage fee, and private pricing supplements that control for institutions.
For most individuals, the exit is an intermediary's
New Dashboard onboarding is for business entities; existing individual accounts keep withdrawal rights and EU residents can redeem USDG directly, but a new US individual's eligibility is not established and the PAXG page points individuals to exchanges. PayPal's terms list a permitted delay by Paxos among the reasons PYUSD service may be unavailable.
Why it matters
Par redemption is a promise to verified customers. A holder on an exchange or in a PayPal balance gets that venue's price, hours and rules, and in stress the venue's own solvency.
Mitigation / verification
Check whether your venue is a direct Paxos customer and how it handles redemptions; for PAXG, confirm your holding appears in the paxg.com allocation lookup (it does not resolve for tokens held on exchanges).
One address for pause and freeze
An address with no contract code holds the pause and asset-protection roles on PAXG, USDP, PYUSD and USDG on Ethereum, plus the admin role on USDP and PYUSD; whether one key or a multi-party signing system stands behind it is not public. All four Solana mints share one freeze authority and permanent delegate.
Why it matters
These powers are lawful and disclosed, and Paxos has used them on law enforcement direction. Their concentration at one address makes its signing arrangements a dependency for every holder, and a permanent delegate can move or burn tokens from any account.
Mitigation / verification
Read the freeze and seizure sections of the PAXG and stablecoin terms; watch the role-holder addresses for changes (AltStreet's reads are dated October 30, 2026).
A compliance record under remediation
The August 2025 consent order found a deficient anti-money-laundering program, a breach of a 2020 letter agreement and transaction monitoring failures; the OCC conditioned the national charter on ring-fenced compliance spending through 2027 and prior approval of senior hires.
Why it matters
The reserves were never found short, and the order credits Paxos's cooperation; the risk is to the franchise (licensing conditions, partner relationships, further regulatory action) rather than to the backing.
Mitigation / verification
Look for OCC public enforcement actions and any further DFS statements; the ninety-day status report under the order is not public.
PAXG fees are in motion
Creation fees are waived only through January 1, 2027; redemption fees moved to a 30-day-net schedule on September 1, 2026; the terms reserve a storage fee charged by minting new tokens to Paxos; fees change 'effective upon posting'.
Why it matters
A holder's all-in cost depends on the schedule in force at redemption, and a dilution storage fee would reduce every holder's gold entitlement without a cash charge.
Mitigation / verification
Reread the PAX Gold Fees support article and section 15 of the PAXG terms before redeeming; the current schedule and its date are quoted in this review.
Attestations examine an instant
KPMG's reports cover token counts and reserve assets at 5:00 PM Eastern on two days a month; they do not audit Paxos, name the banks or list the bars, and the USDG report is addressed to a Singapore regulatory submission.
Why it matters
Backing between report dates, the issuer's own solvency and operational controls are outside the reports' scope.
Mitigation / verification
Compare the attested Ethereum figure with totalSupply at the report block yourself (the contracts and blocks are listed in this review's evidence); read the FDIC pass-through disclosure for the depository list.
ASRisk signals to watch
- A change to the Ethereum role-holder addresses or a new implementation behind any proxy without a published notice.
- A mint outside the rate limits of the SupplyControl contracts, or a repeat of the October 15, 2025 erroneous 300 trillion PYUSD mint.
- An attestation posted late, with a qualified opinion, or showing reserves below tokens outstanding.
- A storage fee notice under section 15.2 of the PAXG terms.
- An OCC enforcement action or a further DFS statement on the 2025 order.
- A change in PayPal's obligation to buy and sell PYUSD at $1.00, or a Paxos minting suspension under section 2.2.2 of the stablecoin terms.
Regulatory & Legal Posture
Security Status
Asset-backed tokens issued by a national trust bank under published terms; Paxos treats PAXG as a warehouse-receipt-like claim on allocated gold and the dollar tokens as redeemable payment instruments. The SEC staff's 2023 position that BUSD was a security ended without action in July 2024, per Paxos. The tokens are not registered securities and are not deposits.
Paxos Trust Company, N.A. is a national trust bank (OCC Charter No. 25379, converted December 12, 2025 from a New York limited purpose trust charter granted May 2015) that takes no deposits and is not FDIC insured; its activities are limited to trust activities under nine written conditions. USDG is issued by a Singapore major payment institution and a Finnish electronic money institution with a MiCA white paper on the ESMA register. Paxos Securities Settlement Company holds a temporary SEC clearing agency registration (May 27, 2026). No Paxos entity is an SEC-registered adviser, broker-dealer or transfer agent; BrokerCheck returns nothing for Paxos or itBit.
- New York Department of Financial Services: limited purpose trust charter to itBit Trust Company, May 2015; PAX authorized September 10, 2018; PAXG and BUSD September 5, 2019; order to cease minting BUSD February 13, 2023; consent order August 7, 2025 ($26,500,000 penalty; $22,000,000 minimum compliance spend 2025 to 2027; violations of 3 NYCRR 116.2, Banking Law 44 and 23 NYCRR 504.3 and breach of the 2020 Letter Agreement). Paxos no longer appears on the DFS regulated-entities table after the OCC conversion, and no Paxos token is on the DFS Greenlist.
- Office of the Comptroller of the Currency: preliminary conditional approval for a de novo charter April 23, 2021; Conditional Approval No. 1358, December 12, 2025, converting Paxos Trust Company, LLC to Paxos Trust Company, National Association (Charter 25379; main office 71 Fifth Avenue, New York; no deposits; not FDIC insured; ultimate parent Kabompo Holdings, Ltd.). Nine conditions enforceable under 12 USC 1818, including $15 million tier 1 capital, 180 days of operating expenses in liquid assets, prior no-objection for USDG on the multi-jurisdictional platform and for senior officers, GENIUS Act conformance, and $7.25 million (2026) and $8.5 million (2027) of compliance spending tied to the DFS order. Listed as a national trust bank as of September 30, 2026.
- Securities and Exchange Commission: Division of Trading and Markets no-action letter, October 28, 2019 (Paxos Settlement Service); Wells notice February 3, 2023 alleging BUSD was an unregistered security and termination notice July 9, 2024, both per Paxos; Release No. 34-105562, May 27, 2026, granting Paxos Securities Settlement Company temporary registration as a clearing agency (Robinhood supported; DTCC raised questions). Paxos is not a party to SEC v. Binance and is referred to there only as 'Trust Company A'. Kabompo Holdings, Ltd. (CIK 1587702): six Form Ds, 2013 to 2021, all Rule 506(b), the last reporting $301,595,877 sold to 20 investors. AltStreet's enforcement tables (33,984 SEC and FINRA actions; 38,226 parties) contain no row for Paxos, itBit or Kabompo.
- Other regulators: Monetary Authority of Singapore directory lists Paxos Global Pte. Ltd. and Paxos Digital Singapore Pte. Ltd. as major payment institutions (digital payment token services); Finland's FIN-FSA lists Paxos Issuance Europe Oy as an electronic money institution and the ESMA register carries its USDG, EUROe and eUSD white papers; the Abu Dhabi FSRA register could not be reached; Connecticut Department of Banking consent order July 23, 2020 ($10,000 civil penalty, $7,500 back fees, neither admitting nor denying unlicensed money transmission since May 2015).
- Courts: Paxos Trust Company, LLC, Paxos Holdings LLC and Kabompo Holdings, Ltd. are defendants in Sizemore v. Zhao (S.D. Fla. 1:23-cv-21261), a putative class action over Binance's alleged sale of unregistered securities; the April 9, 2026 order denying the Binance defendants' motion to compel arbitration does not rule on claims against Paxos, and the pleadings were not retrieved. CourtListener, PACER and New York eCourts were not reachable or not used; bankruptcy claims naming Paxos were not searched. Executive name searches in AltStreet's enforcement tables returned nothing for the CEO or the six directors.
Disclosure Quality
Partial: monthly third-party attestations with per-chain supply and instrument-level reserves, complete published terms and a full PAXG fee schedule; against that, no issuer financial statements, anonymized reserve banks, no bar list, no named ultimate parent on the site, and undated marketing figures.
Custody Model
Gold held by Paxos Trust Company for PAXG holders on a segregated basis in Brink's and ICBC Standard Bank vaults in London; dollar reserves in segregated accounts at Federal Reserve-regulated institutions, overnight Treasury repo and Treasury bills (US tokens) and in MAS- and CSSF-supervised accounts, government money funds and bills (USDG). Token registers on public chains administered by Paxos with pause, freeze and upgrade powers.
Regulatory Backing
OCC supervision of the national trust bank under 12 USC 1818-enforceable conditions; the GENIUS Act's reserve requirements for permitted payment stablecoin issuers, which the US attestations say Paxos applies; the MAS Letter of Undertaking on USDG reserves; Finland's electronic money and MiCA rules for Paxos Issuance Europe.
Tax Treatment
Reporting
Not stated on the pages AltStreet captured. Paxos's support site carries a tax reporting article whose content was not captured; PayPal handles PYUSD reporting for its own customers under its terms.
Not stated.
Income Character
Questions to put to a tax adviser
The dollar tokens pay the holder no income; a disposal at $1.00 ordinarily has no gain. PAXG's value moves with gold, so a sale or redemption is a disposal of a gold interest, and how US law treats a token representing allocated physical gold (including whether collectibles rates apply) is a question for a tax adviser, not something Paxos's pages answer. PayPal's PYUSD rewards are PayPal's payments under its own terms.
Limitation
AltStreet is not a tax adviser; Paxos publishes no tax guidance in the pages captured.
Special Considerations
- Whether a PAXG redemption into unallocated or allocated gold is a taxable disposal in your jurisdiction.
- How your exchange or PayPal reports your token transactions.
- Whether the dormancy charge or a future dilution storage fee affects your basis.
Account Suitability
Taxable
Yes, through the venues that list the tokens.
Roth IRA
Not addressed by Paxos; depends on your custodian's willingness to hold the tokens.
Traditional IRA
As above.
HSA
Not applicable.
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AltStreet Data Layer
What the data actually shows
Twenty-four months of Ethereum supply reads and the attestation series give a dated record of each token's size and of where it lives.
PYUSD down 24% from year end across all chains
3,604.6M tokens on December 31, 2025 to 2,747.6M on September 30, 2026 (attestations); on Ethereum 2,920.3M at the end of February 2026 to 1,686.9M at 23:59 UTC on September 30 (month-end chain reads), as Solana (747.8M) and Arbitrum (293.4M) grew.
What this means
The issuance page's undated '$4B+' does not match any 2026 report date AltStreet could find.
USDG lives mostly off Ethereum
Of 3,165.0M USDG on September 30, 2026, 1,423.0M sat on X Layer, 692.6M on Robinhood Chain and 652.4M on Solana against 320.7M on Ethereum.
What this means
Supply and liquidity for USDG depend on two exchange-operated chains and Solana more than on Ethereum.
PAXG more than doubled, then eased
Ethereum PAXG rose from 196,764 (October 31, 2024) to 514,129 (March 31, 2026), fell to 428,830 (August 31) and stood at 442,891 on October 30, 2026; all-chain attested supply 435,306 on September 30.
What this means
Gold-token demand peaked in the first quarter of 2026 on this record; the fee schedule changed on September 1.
USDP is a small legacy token
109.7M on Ethereum in October 2024, 20.8M on October 30, 2026; Paxos no longer publishes its unaudited reserve self-reports.
What this means
USDP's economics are a rounding error next to PYUSD and USDG; its terms and attestations continue.
Chain and attested token counts agree exactly
At 20:59:59 UTC on September 30, 2026, Ethereum totalSupply equaled the attested Ethereum count for all four live tokens to the whole token.
What this means
The token-count side of the reserve reports can be independently checked against the chain, and it checks; the reserves rest on KPMG's examination.
PAXG's on-chain fee ended in July 2024
feeRate read 0.02% at every month end from August 2019 to June 2024 and zero from July 31, 2024 (block 20,428,928); the June 2, 2026 implementation removed the fee code.
What this means
The page's zero-fee claim is dated by the chain to two years before the code change; the schedule changing now is creation and redemption, not transfer.
A 300 trillion PYUSD mint, reversed in 22 minutes
Ethereum Transfer logs: 300,000,000,000,000 PYUSD minted to supply controller 0x2fb074FA59c9294c71246825C1c9A0c7782d41a4 at 19:12:23 UTC on October 15, 2025 (block 23,585,095) and burned from the same address at 19:34:35 UTC (block 23,585,206).
What this means
The rate-limited SupplyControl contracts now on the four tokens cap what one controller can mint per day; the largest PYUSD controller still allows 24 billion a day.
Freezes come in list-wide batches
371 distinct addresses frozen across the four Ethereum tokens since deployment, 258 on all four; 151 in a batch on January 3 and 4, 2024; 13 wipes in all, including the four FTX-linked PAXG addresses in December 2022.
What this means
The freeze power is exercised mainly as a shared blocklist; a holder's exposure is to that list and to the single address that administers it.
Data as of 2026-10-30 . AltStreet review evidence layer . Public-source analysis
Full datasetDecision Fit
Investor Fit
Who this works for, who it does not, and what level of patience and complexity tolerance the platform really demands.
Payment companies, exchanges and treasuries that can onboard as direct customers
Par redemption with no fee, monthly KPMG attestations that reconcile to the chain, a national trust bank issuer and multi-chain supply. The consent order and OCC conditions are diligence items, not disqualifiers, for a counterparty that reads them.
Individuals who want gold exposure on-chain and accept exchange liquidity
PAXG is allocated, attested and redeemable in kind from 430 ounces, with no storage fee today; most individuals' exit is an exchange market, the fee schedule is in motion, and the token sits under Paxos's freeze and upgrade powers.
Holders who need yield from the token itself
PYUSD, USDP and USDG pay nothing to holders by design; the yield-bearing USDL was wound down in December 2025.
Holders who need deposit insurance or a bearer asset outside issuer control
The tokens are not deposits and carry no FDIC or SIPC protection; Paxos can pause, freeze, seize and upgrade.
Tradeoffs
Key Tradeoffs
The attraction of pre-IPO access is real, but every benefit comes bundled with a corresponding liquidity, transparency, or pricing cost.
Backing
Reports examine an instant and do not audit Paxos; banks anonymized, no bar list.
Access
Direct onboarding for business entities only; individuals hold through intermediaries.
Regulation
Those conditions exist because of a 2025 consent order finding systemic AML failures.
Control
Powers concentrated in one address across four Ethereum tokens and one authority across four Solana mints.
Avoid
Who This Is Not For
This section should be read as a filter, not an afterthought. If you need income, simplicity, or near-term access to capital, the structure is working against you.
Anyone expecting to open a new individual account
New Dashboard onboarding is for business entities; existing individual accounts keep withdrawal rights, and EU residents have a USDG redemption route.
Holders seeking yield
The dollar tokens pay holders nothing; reserve returns go to Paxos and its distribution partners.
Holders who need an audited issuer balance sheet
Paxos Trust Company's financial statements are not public; the attestations cover token backing only.
Editorial View
AltStreet Perspective
The compressed version of the review: what matters, what marketing tends to obscure, and how we would frame the platform for a serious allocator.
Verdict
The question with a stablecoin or gold token is whether the backing is there and whether you can get it. On the first, Paxos publishes monthly attestations by a Big Four firm, printed by chain and by instrument, and AltStreet could reconcile the token counts exactly to the contracts; the reserves themselves rest on the accountant's examination. On the second, the answer depends on who you are: a verified customer redeems at par with no fee, and most individuals hold through an exchange or PayPal and get that venue's exit. The company spent 2025 settling a consent order that found its compliance program deficient for years and converting to a national charter conditioned on fixing it. The enforcement findings cited here do not establish a reserve shortfall; they do make the issuer's terms, fees and role holders the diligence that matters.
Positioning
Among the tokenized asset issuers AltStreet covers, Paxos sits between Franklin Benji (an SEC-registered fund with audited statements, open to retail) and the private tokenized fund shelves (Superstate, Ondo): a bank-chartered issuer with more frequent third-party reserve examinations than the fund shelves publish, no audited issuer statements of the kind the registered products file, and new onboarding narrower than most.
The Bottom Line
Attested, redeemable at par and bank-chartered, with a 2025 consent order behind the charter, new onboarding for businesses only and token controls that rest with Paxos.
Action
Next Steps
If you still want to engage after reading the review, these are the practical next moves that reduce avoidable mistakes.
Decide which access question applies to you: a new account (business entities), an existing individual account moved to the Dashboard, or an EU USDG redemption; otherwise your counterparty is the exchange or PayPal, and their terms govern your exit.
Read the latest attestation for your token on paxos.com and compare its Ethereum figure with totalSupply at the report block (contracts listed in the evidence below).
For PAXG, read the PAX Gold Fees support article and section 15 of the PAXG terms; note the January 1, 2027 end of the creation waiver and the reserved storage fee.
Read the August 7, 2025 DFS consent order and the OCC's Conditional Approval No.
1358; look for subsequent OCC actions.
For PAXG held in self-custody, confirm your allocation on paxg.com; for tokens on an exchange, ask the exchange whether it is a direct Paxos customer.
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Deal Intelligence →Appendix
Sources, Disclosures, and Supporting Context
The lower section is structured like a report appendix: relationship context first, adjacent reading second, and evidence last.
Report Appendix
Disclosure
Relationship and compensation context
+
Report Appendix
Disclosure
Relationship and compensation context
Report Appendix
Related Resources
Adjacent platform comparisons, frameworks, and category links
+
Report Appendix
Related Resources
Adjacent platform comparisons, frameworks, and category links
Further Reading
Related Resources
Adjacent frameworks and reviews that help place the platform in a broader allocation or due-diligence context.
Frameworks
- ->Attestation vs Audit
- ->Reserve Report
- ->Reserve Reconciliation
- ->RWA Proof of Reserves
- ->Proof of Liabilities
- ->Freeze and Blacklist Powers
- ->Administrator Keys
- ->Upgradeable Contracts
- ->Minting and Burning
- ->Redemption Eligibility
- ->Redemption Minimums and Fees
- ->Cash vs In-Kind Redemption
- ->Issuer vs Custodian Insolvency
- ->Bankruptcy Remoteness
- ->Omnibus vs Segregated Custody
- ->Native vs Wrapped Tokens
- ->Stablecoin Settlement Risk
- ->Alternative Assets Due Diligence
Similar Platform Reviews
- Franklin Templeton Benji Review
An SEC-registered government money fund with its register on public blockchains.
- Superstate Review
Tokenized private funds for qualified purchasers on a registered transfer agent's rails.
- YLDS Review
An SEC-registered interest-bearing certificate on-chain from Figure.
Report Appendix
Evidence & Methodology
16 cited passages on file; sources, scope, and how the review was assembled
+
Report Appendix
Evidence & Methodology
16 cited passages on file; sources, scope, and how the review was assembled
Evidence on file
16 supporting passages on file for Paxos and its offerings from 9 source documents, 16 verified by an analyst through 2026-10-31, no discrepancies flagged. Each passage records the metric it supports, the value read from the document, the page, and the verbatim text where the document has it. Terminal subscribers read the passages; open them in the terminal.
- Cited passages
- 16
- Source documents
- 9
- Analyst verified
- 16
- Discrepancies flagged
- 0
Latest analyst verification 2026-10-31; latest extraction 2026-10-31. A discrepancy is a disagreement between two sources, or between a document and a marketing claim, recorded rather than resolved silently.
ASReview Evidence
Methodology
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.
Scope
Paxos Trust Company, N.A. and the affiliates named in its terms; the five issued tokens and the wound-down USDL; the brokerage, custody and settlement lines as described on the site. Pricing supplements, the PSSC rulebook PDFs and the Abu Dhabi register were not obtained or reachable, and the FAQ accordion answers on the product pages render only on click and were not captured: research limitations, not disclosure findings.
Key Findings
- *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
Comparable Platforms
- Franklin Templeton Benji
A registered money fund on-chain, open to US retail.
- Superstate
Private tokenized funds for qualified purchasers.
- YLDS
An SEC-registered interest-bearing certificate on-chain.
FAQ
Frequently Asked Questions
High-intent search questions answered directly, without making users hunt through the full review.
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.