Executive Overview
Enabling compliant global payments for U.S. businesses through regulated stablecoin infrastructure
What Off Ramp does
Off Ramp enables U.S. businesses and nonprofits to pay non-U.S. freelancers small amounts of money (typically <$600/year) using USDC via Circle through User-controlled (non-custodial) wallets, so payments are fast, global, and compliance-manageable.
Fast Payments
Instant USD → USDC conversion and borderless transfers powered by trusted stablecoin infrastructure.
Global Reach
Pay freelancers anywhere in the world without traditional banking delays
Compliance-Ready
Built-in regulatory compliance for U.S. businesses and nonprofits
Why Circle (and which wallet model)
Circle provides Programmable Wallets with two key management models. The difference is about who controls the private keys — which also shapes your compliance responsibilities.
Developer-controlled
Your app controls the keys and can move funds on behalf of users.
- Impact: This creates a heavier compliance burden, since regulators may treat you as a money transmitter.
- You must implement KYC, sanctions screening, AML monitoring, and tax reporting for your users.
User-controlled (non-custodial)
Users control their own keys. Circle provides SDKs, infrastructure, Gas Station (sponsored fees), and Compliance Engine/Transaction Screening hooks.
- Impact: This model carries a lighter burden than developer-controlled, because you don’t directly control funds.
- However, you are still responsible for onboarding your users, running sanctions/KYC checks, and handling reporting.
This is the model Off Ramp uses.
Why the lighter burden is credible:
FinCEN guidance distinguishes unhosted/software wallets from custodial ones. If end users hold their own keys and you don’t accept or transmit value on their behalf, you are generally not considered the money transmitter. In a user-controlled (non-custodial) model, Circle gives you the infrastructure, while you remain responsible for sanctions/KYC policies and tax reporting for your counterparties.
GENIUS Act: why this now works in the U.S.
The GENIUS Act of 2025 establishes the first federal framework for payment stablecoins in the U.S.: it defines permitted payment stablecoin issuers, mandates 1:1 reserves/oversight, and subjects issuers to the Bank Secrecy Act (AML, sanctions, etc.). This gives U.S. companies a clear, federally recognized way to use compliant stablecoins like USDC for payments.
Implication for Off Ramp: by anchoring on USDC issued by Circle (a U.S. issuer operating within the new regime), Off Ramp rides a regulated instrument rather than a gray-area token—materially lowering legal uncertainty relative to pre-GENIUS practices.
Compliance division of labor (manageable in practice)
01
Circle (issuer / infra)
USDC issuance & reserves under GENIUS; wallet infra, Gas Station, and Compliance Engine / Transaction Screening for policy gates.
02
Exchanges/off-ramps
Exchanges/off-ramps (Binance, OKX, Coins.ph, Bitso, etc.): handle local KYC/AML when recipients convert USDC to bank/mobile-money; they carry the "last-mile" compliance in those countries.
03
Off Ramp (platform)
Collect minimal IRS forms and keep books:
- Non-U.S. contractors: W-8BEN on file; no Form 1099 required; book each payout at USD fair market value when sent.
- U.S. contractors (if any): W-9 and file 1099-NEC if ≥$600 in a year.
Note: Circle no longer mints USDC on Tron; supported chains include Ethereum, Solana, and others. If users ever need USDT on Tron for P2P off-ramps, they would swap on a compliant exchange (e.g., Kraken) and withdraw on Tron; that swap step is outside Circle but can happen with Off Ramp via Binance API's.
Why this is operationally sane
No custody = no MSB license
No custody = no MSB license (based on current FinCEN posture for software/non-custodial wallets). You still apply sanctions/KYC screens appropriate to your role, but you avoid the heaviest obligations of hosted custody/payment transmission.
Light IRS load
IRS load is light for non-U.S. payees under $600/year: keep a signed W-8BEN and proper USD-value records; no recurring U.S. tax filings for those recipients.
API automation
API automation: Circle's wallets + Gas Station + screening endpoints make disbursements programmable (batch payouts, fee sponsorship, rules to block risky transfers).
TL;DR
Model
User-controlled (non-custodial) → USDC payouts.
Law
The GENIUS Act gives USDC a clear U.S. legal lane; issuers carry BSA/AML weight.
Burden
Off Ramp's burden is bookkeeping + W-8BEN/W-9 collection, plus sensible sanctions screening—not full money-transmitter regs.
Edge
Global reach with cents-level fees (Solana), off-ramp handled by exchanges where recipients cash out.