The S-Curve

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Half of Anchorage's USDGO stablecoin sits at MEXC

MEXC wallets hold about $579 million of USDGO, a dollar token issued by a US bank. Treasury's new order binds that bank, but the coins reached MEXC through wallets listed as OSL's.

Chart: Half of all USDGO sits in MEXC wallets. USDGO in circulation peaked at $1.4B on 29 September and stands at $1.2B; MEXC wallets hold $579M.
USDGO in circulation and in MEXC wallets. The coins may belong to MEXC, its users or a third party.

Wallets tied to MEXC hold about $579 million of USDGO, or 51.7% of the token’s supply on Solana.Solana RPC, USDGO mint controls and MEXC wallet balances, 6 November 2026. MEXC’s own reserves page lists the two wallets that hold about $446 million of that,MEXC, Proof of Reserves. and the third wallet received its coins from one of them.S-Curve analysis of USDGO transfers on Solana. USDGO is issued by Anchorage Digital Bank, a federally regulated US bank.Anchorage Digital, USDGO Officially Launches Under Federal Oversight. On Friday, Treasury’s FinCEN unit barred US financial institutions from “any transmittal of funds from or to MEXC Global”.FinCEN, Imposition of Special Measure Prohibiting the Transmittal of Funds Involving MEXC Global.

Nothing here suggests that Anchorage or anyone else has broken a rule, and the order has yet to take effect. But it puts a US bank’s token in an awkward place: mostly held at a venue that US banks will soon be barred from dealing with.

How the coins got there

Anchorage issues USDGO, and OSL Group, a Hong Kong-listed company, brands it, with OSL subsidiaries acting as distributors.OSL Group, Officially Launches Regulated Enterprise Stablecoin USDGO. The 207 mints we traced from December 2025 to 28 October, about $1.8 billion in all, went to no MEXC account.

The coins arrived another way. About $583 million moved from one wallet, through four relay addresses, into MEXC wallets, in one case within two minutes. DefiLlama lists that wallet as OSL’s.DefiLlama, OSL wallet list. Who controls the relays is unclear, as is whether the coins belong to MEXC, its users or a third party.

The balance built quickly. MEXC wallets first held over $1 million of USDGO on 8 May, about $210 million by 26 May.DefiLlama, USDGO supply and MEXC balances. Crystal Intelligence counts a $262 million increase in the third quarter,Crystal Intelligence, Who moved stablecoins in Q3. and says exchanges added stablecoins “often ones that carry rewards”. MEXC lists a USDGO/USDT market,MEXC, USDGO/USDT market page. but its reserves page reports USDT, USDC, BTC and ETH only.

Both series from DefiLlama. Direct chain reads on 6 November put MEXC's wallets at 578.8 million of 1.12 billion USDGO on Solana. The coins may belong to MEXC, its users or a third party. Download (PNG) · Data (CSV)
Chart: Half of all USDGO sits in MEXC wallets. USDGO in circulation: peak $1.4B (25 Sep 2026, 1-day average), latest $1.2B (6 Nov 2026); Held in MEXC wallets: peak $584M (3 Oct 2026, 1-day average), latest $579M (6 Nov 2026). Data available as CSV.

What the order reaches

FinCEN’s definition of a bank includes a “trust company organized under the laws of any State or of the United States”,31 CFR 1010.100 definitions. so Anchorage is covered. The order counts “the sending and receiving of funds, including CVC”, its term for crypto. A mint to MEXC or a redemption from it would fall inside that wording.

The rule stops at the US border: it covers an “office within the United States”. An offshore distributor selling to MEXC sits outside that on its face, unless it has a US office or affiliate involved.

FinCEN has said where it expects issuers to stand. In April it proposed that stablecoin issuers comply “with special measures issued pursuant to sections 311, 9714(a), and 2313a”.FinCEN and OFAC, Permitted Payment Stablecoin Issuer AML and Sanctions Programs, proposed rule, 91 FR 18582. Section 9714(a) is the law behind the MEXC order. The same proposal said FinCEN was “not proposing to require a PPSI”, its term for a regulated issuer, “to monitor secondary market activity”. Its examples of that activity include swapping stablecoins “via a digital asset exchange”. That text is a proposal, not a final rule.

What Anchorage can do

The token has a freeze authority, a permanent delegate and a pause function, and none has been used against these wallets. The operative part of the MEXC order names no token or address, while an order to block coins under the stablecoin law must specify them “with reasonable particularity”. In its 2023 FAQ on Bitzlato, FinCEN told institutions to stop transfers “from or to any account or CVC address administered by Bitzlato”.FinCEN, Frequently Asked Questions on the Bitzlato order.

Why USDGO stands out

The other dollar tokens we checked are far less exposed. MEXC wallets hold about 0.5% of USDC and about 4.5% of USD1, on DefiLlama’s figures. Its listed Ethereum wallets hold no RLUSD, PYUSD or USDG, and about 113,000 USAT.

MEXC says it “is operating normally, and user assets remain secure”.MEXC, statement on the FinCEN order, on X. For USDGO holders there, the practical question is how a coin at MEXC gets back to dollars once the order takes effect, if the issuer cannot take it from MEXC directly.

Sources

  1. FinCEN, Imposition of Special Measure Prohibiting the Transmittal of Funds Involving MEXC Global
  2. FinCEN, Frequently Asked Questions on the Bitzlato order
  3. FinCEN and OFAC, Permitted Payment Stablecoin Issuer AML and Sanctions Programs, proposed rule, 91 FR 18582
  4. 31 CFR 1010.100 definitions
  5. Anchorage Digital, USDGO Officially Launches Under Federal Oversight
  6. OSL Group, Officially Launches Regulated Enterprise Stablecoin USDGO
  7. MEXC, Proof of Reserves
  8. MEXC, USDGO/USDT market page
  9. Solana RPC, USDGO mint controls and MEXC wallet balances, 6 November 2026
  10. Crystal Intelligence, Who moved stablecoins in Q3
  11. DefiLlama, OSL wallet list
  12. S-Curve analysis of USDGO transfers on Solana
  13. DefiLlama, USDGO supply and MEXC balances
  14. MEXC, statement on the FinCEN order, on X

Disclosure

This article was drafted by S-Curve Desk, an AI system, from the sources above. Boaz Sobrado reviewed it before publication. Errors: the corrections log, or write to us.