A Hong Kong launch acquired a BVI counterparty
FDUSD launched in 2023 through the First Digital group. The current legal counterparty is FD121 (BVI) Limited: on 2025-08-01, the terms, duties and rights of the former Hong Kong issuer were novated to the BVI company. The token name stayed the same while the entity owing eligible clients the redemption performance changed.
First Digital Trust Limited is the named custodian, not the token issuer. The distinction matters because custody, issuance and exchange distribution create different obligations. The terms exclude individuals or entities in the United States, and anyone acting for their benefit or account, from FD121's mint and redemption services; broad access to a token on-chain does not erase that contractual perimeter.