First Digital USD (FDUSD) Review

First Digital USD (FDUSD) scores 6.6 out of 10 in our stablecoin ratings, seventh of the ten coins rated. It publishes monthly reserve reports with every Treasury bill listed by CUSIP, and its reserves are held apart from the issuer's own funds by a Hong Kong trust company. The score falls short of the regulated issuers above it because the issuer itself, FD121 (BVI) Limited, names no supervisor and says FDUSD will not be licensed under Hong Kong's stablecoin law, and because the banks actually holding the reserves are not named. The basis is desk research of the FDUSD whitepaper, the issuer's June 2026 attestation report, a First Digital release filed with the SEC and the Hong Kong Monetary Authority (HKMA) register, rechecked on 1 November 2026. First Digital Labs' own website sits behind a bot check we could not pass, so its transparency page was not read directly.

How FDUSD scores in stablecoins

The category uses five criteria, each marked 0 to 10 and each worth one fifth of the total, as set out in our ratings methodology.

The arithmetic is a plain average: (8 + 4 + 6 + 7 + 8) / 5 = 33 / 5 = 6.6. No criterion is weighted more than another and no penalty is applied.

Changes from the previous scoring: regulatory oversight fell from 6 to 4 after the whitepaper confirmed that the issuer moved to the British Virgin Islands in August 2025 and that FDUSD will not be licensed under Hong Kong's stablecoin regime. Custody and segregation fell from 9 to 7 because the June 2026 attestation shows the reserves spread across institutions that are not named, held through a custodian in the same group. The overall score moves from 7.4 to 6.6. The other three marks are unchanged.

Strongest criteria: reserve reports and a plain backing model

Reserve transparency (8)

The attesting firm is now named. AOGB CPA Limited signed the report for 30 June 2026 on 10 July 2026, under the ISAE 3000 (Revised) assurance standard. It shows 350,117,619.46 FDUSD in circulation against US$351,727,981.95 in reserves: about US$300.2 million in eight Treasury bills listed by CUSIP and maturity, a US$15 million fixed deposit and US$36.5 million in custody accounts. Supply is broken down by contract on BNB Chain, Ethereum, Sui, Solana, Arbitrum and TON. Three things keep the mark at 8. The engagement gives limited assurance, which the firm says is "substantially less in scope than an audit". The institutions holding the cash are described only by country. And June 2026 is the latest report we could open, because the issuer's report list sits behind the blocked site.

Backing model clarity (8)

The whitepaper describes FDUSD as a fully reserved, fiat-backed coin that pays holders no interest, and the reserve report matches it. One labeling point holds the mark below the 9 given to the clearest issuers: the June report lists the fixed deposit under a heading for government debt held through reverse repurchase agreements, without saying how the two relate.

Weakest criteria: what changed and why

Regulatory oversight (4)

The whitepaper says FDUSD launched in June 2023 from FD121 Limited in Hong Kong and moved to FD121 (BVI) Limited in August 2025, and the June 2026 attestation is addressed to that BVI company. Neither document names a licence or supervisor for the issuer. Hong Kong's licensing regime for fiat-referenced stablecoin issuers took effect on 1 August 2025; the HKMA register, last revised 23 April 2026, lists only Anchorpoint Financial and HSBC. A First Digital release filed with the SEC on 6 October 2026 says the group holds a Hong Kong TCSP licence and two Canadian money services business registrations, and that a licence application for issuing fiat-referenced tokens is pending in Abu Dhabi Global Market. A pending application does not count. The four points reflect the custodian's licence; Tether, whose supervisor is named only in its own terms, receives 5.

Custody and segregation (7)

First Digital Trust Limited is named, registered under Hong Kong's Trustee Ordinance and licensed as a TCSP (no. TC006771). The whitepaper says reserves are kept in "distinct and segregated accounts" and separate from FD121's operating funds. The June 2026 report adds what the earlier mark did not weigh: the custodian is a related party, and much of the reserve sits in accounts it opened in its own name at institutions in Hong Kong, Singapore, Australia, Canada, Luxembourg, the US, the UK, Bahrain and Georgia, plus another Hong Kong trust company in the group, none of them named. The report says each rated institution is graded at least A-2 by S&P Global for short-term credit. The whitepaper's statement that reserves "remain protected" in an FDT bankruptcy is the company's own; we did not see the custody agreement.

Redemption rights (6)

Redemption is documented but conditional: an FD121 Account, completed due diligence, no breach of the terms and no legal restriction. The whitepaper says redemption "may be subject to a redemption surcharge" and elsewhere promises zero-fee minting and redemption "as long as you mint more than you redeem", so a pure redeemer cannot price the exit in advance. No minimum is published.

What the score does not cover

• Peg history. FDUSD fell well below $1 in April 2025 after public allegations against its custodian, which First Digital denied. Peg history is not a criterion, so the episode moves no mark.
• Market depth and exchange concentration. First Digital says Binance remains FDUSD's largest centralized market; liquidity is not scored.
• Contract controls. Freezing powers and upgradeable contracts are outside this rubric.

Our guide on how to assess a stablecoin covers those checks.

FDUSD vs Global Dollar and Tether

Two useful comparisons are Global Dollar (USDG) at 8.4, another dollar coin issued outside the US, and Tether (USDT) at 5.4, whose supervisor is named only in its own terms.

FDUSD scores a point higher than USDG on custody, but USDG leads on every other criterion, by five points on oversight and three on redemption, mainly through named supervisors and plain 1:1 redemption. Against Tether, FDUSD leads on four criteria and trails by a point on oversight.

Who the score suits

The rating helps readers weigh line-by-line reserve reports against an issuer with no supervisor. It suits institutions that can open an FD121 Account better than holders who will only ever sell on an exchange. This is an assessment of published documents, not a recommendation to hold FDUSD.