AMLBot’s analysis covering 2023–2025 highlights a significant division in how stablecoin freezing activities have been conducted in terms of scale and methodology. During this period, Tether (USDT) blacklisted approximately 7,268 addresses, effectively freezing assets worth around $3.29 billion. On the other hand, Circle (USDC) undertook freezing actions on 372 addresses involving $109 million, driven solely by court or regulatory directives. The report underscores a nearly 30-fold difference in both value and address count in favor of USDT. It also delves into how address freezing processes are seamlessly integrated into real investigative workflows on Ethereum and especially the Tron network.
USDT’s Massive Scale
According to the analysis, Tether has frozen a total of $3.29 billion across the ERC-20 and TRC-20 lines. Tron emerges as the dominant network, hosting over 53% of the frozen USDT, translating to $1.75 billion. The report reveals an acceleration in Tether’s blacklisting activities by late 2023, with a near-vertical increase projected into 2024–2025. Unlike sporadic enforcement, Tether’s sanctioning process is continuous and progressive. Currently, frozen USDT assets on Ethereum amount to approximately $1.54 billion, compared to $109 million for USDC on the same network.
A distinguishing feature of Tether’s strategy is the transformation of its “freeze + burn + reissue” approach into a refund and compensation mechanism. The report highlights that July 2024 saw USDT freezes surpass $130 million, with $29.6 million linked to Cambodia-based Huione Group particularly standing out on the Tron network. By the end of 2025, instances where over $25-30 million in “burned” coins peaked, illustrating Tether’s operational cycle that binds freezing with post-investigation permanent liquidation and refund steps.
USDC’s Court-Mediated Model
Circle operates within a narrower framework depicted in the report, where USDC freezes follow an “access restriction” logic, solely triggered by existing laws, regulations, or court mandates. The data between 2023–2025 showed 372 addresses and a total of $109 million characterized by “high but rare” spikes, indicating a lack of continuity in daily flow. Circle notably avoids employing coin burning and reissuing mechanisms, with assets remaining static until legal approval is acquired.
The report mentions Tether’s partnerships with over 275 law enforcement entities across 59 jurisdictions and their engagement with more than 2,800 addresses alongside U.S. law enforcement. This wide latitude raises concerns over privacy and censorship. An example noted is the freezing of approximately 44.7 million USDT in April 2025 at the behest of Bulgarian police, which led to litigation by Riverstone Consultancy, illustrating how rapid response capabilities can result in legal risks. Additionally, delays caused by the multi-signature approval process have been associated with losses of around $78 million since 2017, highlighting the critical balance between “rapid intervention” and “governance security.”
