First Digital Labs has transitioned the issuance of FDUSD from Hong Kong to a newly incorporated entity, FD121 (BVI) Limited, based in the British Virgin Islands (BVI). This move is part of a broader plan to ensure FDUSD remains universally accessible and structurally aligned for long-term growth, while delivering uninterrupted service to all users.
The regulatory environment for stablecoins continues to evolve. Hong Kong has passed a legislative framework for stablecoin oversight, setting the foundation for future supervision of digital assets. In parallel, jurisdictions such as the European Union (via the Markets in Crypto-Assets or “MiCA” regulation) and the United States (through the GENIUS Act) are advancing their approaches to fiat-referenced digital currencies.
First Digital Labs welcomes the emergence of clear regulatory frameworks. We believe that well-defined regulation is essential for responsible innovation, user protection, and long-term institutional trust. The transition to a BVI-based issuer reflects a planned and deliberate step within our broader regulatory roadmap. It gives us the structural flexibility to continue operating FDUSD globally today, while building toward integration into licensed regimes across multiple jurisdictions.
BVI offers a well-recognized and business-friendly legal framework that supports digital asset operations with the flexibility required to interface with emerging regulatory regimes. This structure enables us to continue operation FDUSD under consistent standards, while building toward a globally integrated and compliant model.
What Stays the Same
No changes have been made to how end-users interact with FDUSD. FDUSD continues to be backed 1:1 by USD-denominated reserves. Our reserve custody, governance standards, and monthly attestations remain unchanged and publicly available. Minting and redemption services remain fully operational to the eligible clients through the same client portal and workflows.
There is also no material impact on terms and conditions. Existing FD121 account holders are not required to take any action. Agreements previously held with FD121 Limited (Hong Kong) will be automatically assigned to FD121 (BVI) Limited. Updated terms and conditions reflecting this change are available at: https://firstdigitallabs.com/legal.
Looking Ahead
This change allows us to continue serving our users without disruption, while preparing FDUSD to meet the long-term needs of a growing, global user base. We are actively laying the groundwork for a digital dollar that can operate across jurisdictions, supported by a regulatory footprint that reflects its international utility. As part of this strategy, we are progressing toward licensing in select markets and expect to provide further updates on the next phase of our roadmap in early 2026.
First Digital Labs remains committed to delivering a secure, transparent, and reliable stablecoin. This relocation is one of several structural enhancements we are making to ensure FDUSD continues to meet the needs of professional market participants operating across today’s interconnected and global digital asset ecosystem.
DISCLAIMER
This publication is general in nature and is not intended to constitute any professional advice or an offer or solicitation to buy or sell any financial or investment products. You should seek separate professional advice before taking any action in relation to the matters dealt with in this publication. Please note our custody services of the reserves are provided by First Digital Trust Limited.










