The partner: Tether and the reputational question
The company behind USDT
Tether was founded in 2014 and issues USDT, the first and by far the most widely used stablecoin, a token that is meant to maintain a value of one United States dollar and that is backed, according to the issuer, by a portfolio of reserve assets.1 The company is not a bank and is not supervised as one in any of the major financial centres. The group consists of several entities. In the enforcement order of the United States Commodity Futures Trading Commission of 2021 they appear as Tether Holdings Limited, Tether Limited, Tether Operations Limited and Tether International Limited.2 The group has close historical links with the exchange Bitfinex, which shared management and ownership with it. Its chief executive since his promotion in October 2023 has been Paolo Ardoino, who before that was chief technology officer and represented the company at the launch of Plan ₿ in that capacity.3
The scale of the business has grown enormously since Plan ₿ was launched. At the launch in March 2022 about USD 80 billion of USDT circulated.4 According to the attestation for 30 June 2026, prepared by the accounting firm BDO and published on 31 July 2026, about USD 184.6 billion of USDT was outstanding. Total assets of USD 187.75 billion exceeded liabilities of USD 183.64 billion by USD 4.11 billion, half the buffer reported three months earlier. The reserves consisted mainly of United States Treasury bills of close to USD 115 billion, together with about 146 tonnes of gold and about 98,900 bitcoin, and the decline of the buffer was attributed to falls in the prices of gold and bitcoin during the quarter.5 An attestation confirms the composition of reserves at a given date. It is not a full audit of the company's accounts, which Tether has long promised and which critics continue to demand.6
The settlements of 2021
Two enforcement actions in the United States define the regulatory record with which Tether entered the partnership with Lugano. On 23 February 2021 the New York Attorney General announced a settlement with Bitfinex and Tether. The investigation had found that Tether had misrepresented that every USDT was backed one-to-one by United States dollars, that "starting no later than mid-2017, Tether had no access to banking" and that Bitfinex had concealed a loss of about USD 850 million connected with the Panama-based payment processor Crypto Capital Corp. The companies agreed to pay USD 18.5 million, to stop trading with New York residents, to submit regular reports on the segregation of corporate and client funds and on transfers between Bitfinex and Tether, and to publish the composition of the reserves backing USDT by category.7
On 15 October 2021 the CFTC imposed a civil penalty of USD 41 million on the Tether entities and USD 1.5 million on Bitfinex. It found that between 1 June 2016 and 25 February 2019 Tether had falsely claimed that USDT was fully backed by corresponding fiat currency, that the reserves had included unsecured receivables and non-fiat assets, and that Tether had held sufficient fiat reserves to back the tokens in circulation on only 27.6 per cent of the days in a 26-month sample period from 2016 to 2018. Tether had also promised audits that never took place.8 Both settlements resolved the proceedings by agreement. They established facts as found by the authorities and imposed sanctions, but they did not involve criminal convictions, and Tether has since presented its regular attestations and the composition of its reserves as evidence that the shortcomings of that period have been remedied.9
Notes
- Plan ₿ Foundation, "Chi siamo" (above) (Tether founded in 2014, issuer of the leading stablecoin). ↩
- Commodity Futures Trading Commission, press release 8450-21 of 15 October 2021, https://www.cftc.gov/PressRoom/PressReleases/8450-21. ↩
- Allen, "Death, taxes and crypto" (above) (Ardoino as chief technology officer in 2022); "Lugano's Plan ₿ ", Tio.ch (above) (Ardoino as chief executive in 2026); Wikipedia (used as a last resort), "Tether (cryptocurrency)", https://en.wikipedia.org/wiki/Tether_(cryptocurrency) ("In October 2023, Paolo Ardoino, the chief technology officer for Tether, was promoted to CEO"). ↩
- Allen, "Death, taxes and crypto" (above) (about USD 80 billion of USDT in circulation). ↩
- Stablecoin Insider, report on the attestation for the second quarter of 2026 (above), reporting the BDO attestation released on 31 July 2026 (total assets USD 187.75 billion, liabilities USD 183.64 billion, excess reserves USD 4.11 billion after USD 8.23 billion at the end of the first quarter; about 146.2 tonnes of gold and about 98,933 bitcoin). ↩
- CFTC, press release 8450-21 (above) (promised audits that never took place). ↩
- Office of the New York State Attorney General, press release "Attorney General James Ends Virtual Currency Trading Platform Bitfinex's Illegal Activities in New York", 23 February 2021, https://ag.ny.gov/press-release/2021/attorney-general-james-ends-virtual-currency-trading-platform-bitfinexs-illegal. ↩
- CFTC, press release 8450-21 (above). ↩
- CFTC, press release 8450-21 (above) (order "simultaneously filing and settling charges" against the Tether entities); New York Attorney General, press release of 23 February 2021 (above) (settlement agreement). Neither release states whether the companies admitted or denied the findings. ↩
For general information only. This article does not constitute legal or tax advice, does not replace advice on an individual case and creates no lawyer-client relationship. It reflects the legal position as of August 2025.