UVZIuJyYwnZVaSsUFOZizwT

KYCO: Know Your Company

Reveal Profile

14 December 2025

1) Overview of the Company

First Digital Group is a stablecoin issuer and digital asset infrastructure provider that operates as a global leader in compliant digital payment solutions. The company is best known for issuing FDUSD, a USD-pegged stablecoin that has achieved significant market penetration since its launch, reaching over $1 billion in market capitalization within its first four months and subsequently achieving a peak circulation exceeding $4.4 billion with more than $2 trillion in cumulative trading volume.

First Digital operates through a multi-jurisdictional structure with entities in Hong Kong, Gibraltar, and the British Virgin Islands to provide institutional-grade custody and stablecoin issuance services. The company maintains a compliance-first operating model with licenses and registrations in key financial centers, serving regulated financial institutions, digital asset exchanges, market makers, and fintech innovators across APAC, UK, and Middle East markets.

In December 2025, First Digital announced a significant strategic expansion with the launch of its “Finance District” platform, a decentralized finance ecosystem specifically designed for the artificial intelligence economy. This initiative positions the company at the intersection of blockchain technology, decentralized finance, and AI infrastructure, targeting the emerging market where AI agents are projected to handle or influence $30 trillion in transactions by 2030.

The company expects to report approximately $80-90 million in unaudited revenue for 2025 and has entered into a non-binding letter of intent for a proposed business combination with CSLM Digital Asset Acquisition Corp III, a special purpose acquisition company, with the intent to become publicly listed on a U.S. national securities exchange.

2) History

First Digital was originally established in 2017 under Legacy Trust Company before becoming an independent entity in 2019. The company underwent a significant corporate restructuring in 2022 and is now operating under Gibraltar-based First Digital Group Ltd as its parent company.

The company’s development has been marked by progressive funding rounds that supported its growth trajectory. In March 2020, First Digital raised $3 million in seed funding led by Nogle Capital Management, followed by a $5 million funding round in April 2021 led by Kinetic Capital. The company subsequently completed a Series A round of $20 million in May 2022 led by Arcane Group, bringing its total funding to $25.2 million.

First Digital’s flagship product FDUSD was launched as a USD-pegged stablecoin and quickly gained significant market traction. The stablecoin achieved native deployment across multiple blockchain networks including Ethereum, Binance Smart Chain, Sui, and Solana, providing users with access to ultra-fast transaction speeds and cross-chain compatibility.

In August 2025, the company implemented a strategic transition of FDUSD issuance to a British Virgin Islands-based structure through FD121 (BVI) Limited to provide enhanced structural flexibility for global operations and future regulatory compliance across multiple jurisdictions.

A major milestone occurred in December 2025 with the launch of the Finance District platform, representing First Digital’s expansion into AI economy infrastructure. This same month, the company announced a proposed business combination with CSLM Digital Asset Acquisition Corp III, marking its transition toward becoming a publicly traded entity.

3) Key Executives

Based on the available source material, specific information about First Digital’s current executive leadership team is limited. Vincent Chok serves as Chief Executive Officer of First Digital and has been the primary spokesperson for the company during public disputes and strategic announcements. Chok has represented the company in media interviews and official statements, including during the April 2025 dispute with Justin Sun where he clarified that First Digital acted purely as a custodian for TUSD operations.

The company has assembled a distinguished advisory board comprising industry leaders from blockchain technology, institutional finance, and digital payments sectors. The board includes Sandy Peng (Co-Founder of Scroll), Luc Froehlich (Chief Commercial Officer at RAK Digital Assets Oasis), Chris Harmse (Co-Founder and Chief Business Officer at BVNK), Praful Morar (Former Chief Strategy & Expansion Officer at Nuvei), and Neil Tan (Former Chairman of the FinTech Association Hong Kong and Member of the HKSAR Web3 Task Force).

Without access to comprehensive company documentation, the specific details regarding other senior leadership positions including Chief Financial Officer, Chief Operating Officer, Chief Compliance Officer, or Chief Technology Officer cannot be accurately determined from the current source material. The strategic nature of First Digital’s platform operations and regulatory compliance requirements across multiple jurisdictions suggest the company likely maintains technical and operational leadership with expertise in blockchain technology, financial services regulation, and digital asset infrastructure.

4) Ownership

First Digital operates with a complex ownership structure that has evolved significantly since its founding. The company is now operating under Gibraltar-based First Digital Group Ltd as its parent company, while FD121 (BVI) Limited, registered in the British Virgin Islands, functions as the issuer of FDUSD stablecoin. This transition to a BVI-based structure was implemented in August 2025 to provide structural flexibility for global operations and future regulatory compliance across multiple jurisdictions.

First Digital has secured funding through multiple investment rounds, demonstrating institutional confidence in its business model. The company raised $3 million in seed funding in March 2020 led by Nogle Capital Management, followed by a $5 million funding round in April 2021 led by Kinetic Capital, and subsequently a Series A round of $20 million in May 2022 led by Arcane Group. The investor base includes notable venture capital firms specializing in digital assets and blockchain technology, with Arcane Group, Hack VC, Kenetic Capital, and Nogle having provided equity backing across multiple funding rounds, bringing total funding to $25.2 million as of 2022.

A significant ownership development occurred in December 2025 when First Digital Group entered into a non-binding letter of intent for a proposed business combination with CSLM Digital Asset Acquisition Corp III (KOYN), a special purpose acquisition company. Upon completion of this transaction, the combined company is expected to be publicly listed on a national securities exchange in the United States. The proposed merger transaction represents a transformational change in First Digital’s ownership structure, potentially transitioning from a private company backed by venture capital investors to a publicly traded entity with access to public capital markets.

First Digital maintains operations across multiple jurisdictions including Hong Kong, where First Digital Trust Limited provides custody services, Gibraltar for the parent company structure, and the British Virgin Islands for stablecoin issuance operations. This multi-jurisdictional structure supports the company’s compliance-first operating model with licenses and registrations in key financial centers.

5) Financial Position

First Digital expects to report approximately $80-90 million in unaudited revenue for 2025, positioning itself as a substantial player in the digital asset infrastructure sector during a period of rapid growth in stablecoin adoption and blockchain-based payment systems. The company’s financial trajectory demonstrates strong momentum through its flagship product FDUSD, which achieved remarkable market penetration metrics, reaching over $1 billion in market capitalization within its first four months of operation and subsequently surpassing a peak circulation of more than $4.4 billion. The stablecoin has processed more than $2 trillion in cumulative trading volume since launch, indicating substantial revenue-generating activity and deep market liquidity.

The company’s revenue model benefits from the broader digital assets and currencies investment surge, which attracted $8.4 billion globally in the first half of 2025 compared to $10.7 billion for all of 2024. This sector growth trajectory positions First Digital within a rapidly expanding market segment where institutions increasingly seek compliant, transparent stablecoin solutions.

First Digital’s funding history reflects progressive institutional confidence, having raised $25.2 million across multiple investment rounds. The company secured $3 million in seed funding in March 2020 led by Nogle Capital Management, followed by a $5 million round in April 2021 led by Kinetic Capital, and a Series A round of $20 million in May 2022 led by Arcane Group. This funding progression demonstrates investor validation of the company’s business model and growth prospects.

A transformational financial development occurred in December 2025 when First Digital Group entered into a non-binding letter of intent for a proposed business combination with CSLM Digital Asset Acquisition Corp III (KOYN), a special purpose acquisition company. This potential merger represents a pathway to public market access and enhanced capital availability for scaling operations and expanding the company’s product ecosystem.

The company maintains institutional-grade custody arrangements, with reserves held in segregated accounts through licensed custodian affiliates and supported by independent monthly attestations. This trust framework underpins the company’s revenue model by providing institutional confidence in FDUSD’s backing and compliance standards, essential for maintaining trading volume and market maker relationships.

6) Market Position

First Digital occupies a strategic position in the rapidly evolving stablecoin and digital payments infrastructure sector, operating at the intersection of traditional finance and blockchain technology. The company has established itself as a significant player in the global stablecoin market through its flagship product FDUSD, which has demonstrated remarkable growth metrics since launch, reaching over $1 billion in market capitalization within its first four months and subsequently achieving a peak circulation exceeding $4.4 billion with more than $2 trillion in cumulative trading volume.

The competitive landscape for stablecoin issuers has intensified as blockchain technology gains institutional acceptance, with stablecoin transaction volumes approaching levels comparable to traditional payment networks. First Digital’s market positioning benefits from this broader sector growth, where digital assets and currencies investment surged to $8.4 billion globally in the first half of 2025. This market expansion trajectory positions First Digital within a rapidly growing segment that digital asset platforms are increasingly capturing as institutions seek compliant, transparent stablecoin solutions.

First Digital’s competitive differentiation centers on its compliance-first operating model with licenses and registrations in key financial centers including Hong Kong, Gibraltar, and the British Virgin Islands. The company operates through First Digital Trust Limited in Hong Kong, which provides custody services under Hong Kong’s Trust Ordinance Section 8, while maintaining SOC1 Type 2, SOC2 Type 2, and ISO 27001 certifications. This regulatory infrastructure provides institutional confidence that distinguishes First Digital from less regulated competitors in the stablecoin sector.

The company’s strategic positioning leverages institutional-grade custody arrangements with reserves held in segregated accounts through licensed custodian affiliates, supported by independent monthly attestations. This trust framework underpins First Digital’s competitive advantage by providing institutional confidence in FDUSD’s backing and compliance standards, essential for maintaining trading volume and market maker relationships.

First Digital’s market approach focuses on serving regulated financial institutions and fintech innovators including blockchain start-ups, money service businesses, token issuers, market makers, digital asset exchanges, and family offices across APAC, UK, and Middle East markets. This customer concentration in professional and institutional segments positions the company to benefit from the growing adoption of blockchain technology by traditional financial institutions.

The company’s operational capabilities demonstrate significant scalability, with FDUSD achieving native deployment across multiple blockchain networks including Ethereum, Binance Smart Chain, Sui, and Solana. This multi-chain strategy enhances First Digital’s competitive positioning by providing users with access to ultra-fast transaction speeds, low fees, and high scalability across different blockchain ecosystems.

7) Legal Claims and Actions

First Digital is currently involved in an ongoing legal dispute stemming from a high-profile controversy that erupted in April 2025. On April 3, 2025, the company initiated a defamation lawsuit (Case HCA 680/2025) against Tron founder Justin Sun in the Hong Kong High Court, following public allegations made by Sun regarding First Digital Trust’s operations.

The legal action was prompted by Sun’s public statements on April 2, 2025, where he alleged that First Digital Trust, an affiliated custodian, was “effectively insolvent” and unable to fulfill redemptions related to its prior role managing reserves for the TrueUSD (TUSD) stablecoin. Sun and court documents filed by TUSD’s operator, Techteryx, alleged that First Digital Trust had misdirected approximately $456 million of TUSD reserves into illiquid investments with entities like Dubai-based Aria Commodities DMCC without authorization.

First Digital immediately and publicly refuted these allegations, asserting that the company was “completely solvent” and characterizing the claims as a “typical Justin Sun smear campaign” by a business competitor. The company maintained that its FDUSD stablecoin was fully backed by U.S. Treasury bills and that it had acted purely as a custodian for TUSD operations, following client instructions rather than acting as a fiduciary.

The allegations had immediate market impact, causing First Digital’s FDUSD stablecoin to de-peg from its $1 price, falling to as low as $0.87 on the Binance exchange and resulting in a market capitalization decline of nearly $400 million within 48 hours. However, the FDUSD subsequently recovered its $1 peg after the company published new attestation reports confirming its reserves were fully backed.

In response to the defamation lawsuit, Sun stated he “welcomes any legal process” and reiterated his claims, citing public financial reports allegedly showing that First Digital Trust had negative net assets for three consecutive years. The dispute also drew attention from Hong Kong legislator Johnny Wu, who stated that regulators and lawmakers were investigating allegations involving trust companies.

As disclosed in First Digital’s December 2025 merger announcement, the defamation action against Justin Sun remains ongoing and represents a material legal matter for the company.

8) Recent Media

Media coverage of First Digital has been predominantly positive between 2023 and 2025, focusing on strategic announcements and partnerships, though punctuated by a significant public dispute in April 2025. Throughout 2024 and 2025, the company garnered positive coverage for several key strategic developments, including the November 2024 announcement of its inaugural advisory board featuring industry figures from Scroll, RAK Digital Assets Oasis, and the HKSAR Web3 Task Force.

The company received favorable media attention for strategic partnerships in 2025, including collaborations with BVNK, a stablecoin payment infrastructure provider, to accelerate global adoption of FDUSD, and an integration with Singapore-based MetaComp to facilitate cross-border payments. In December 2025, First Digital launched its Finance District platform, a decentralized finance ecosystem for the AI economy, generating positive coverage across fintech publications.

The most significant positive media event occurred in December 2025, when multiple major outlets including Bloomberg reported that First Digital Group had signed a non-binding letter of intent for a proposed business combination with CSLM Digital Asset Acquisition Corp III, a special purpose acquisition company, with the intent to become publicly listed on a U.S. national securities exchange.

However, First Digital experienced significant adverse media coverage in April 2025 during a high-profile public dispute with Tron founder Justin Sun. Sun publicly alleged that First Digital Trust was “effectively insolvent” and unable to fulfill redemptions related to TUSD stablecoin reserves, claiming the company had misdirected approximately $456 million into illiquid investments without authorization. Sun compared the situation to the FTX collapse and offered a $50 million bounty for information on the matter.

The allegations triggered immediate negative market impact, with FDUSD de-pegging from $1 to as low as $0.87 and losing nearly $400 million in market capitalization within 48 hours. Media coverage extensively documented First Digital’s immediate response, characterizing Sun’s claims as a “typical Justin Sun smear campaign” and announcing legal action. The company successfully defended its position, with FDUSD subsequently recovering its dollar peg after publishing attestation reports confirming full reserve backing.

The dispute generated substantial media attention across cryptocurrency and financial publications, with coverage spanning the initial allegations, market impact, First Digital’s response, and the subsequent legal proceedings. The company’s April 3, 2025 initiation of defamation proceedings against Sun in Hong Kong High Court received widespread coverage, with Sun stating he “welcomes any legal process.”

9) Strengths

Leading Position in Regulated Stablecoin Infrastructure

First Digital has established itself as a significant player in the regulated stablecoin market through its flagship product FDUSD, which has demonstrated remarkable growth metrics since launch. The stablecoin reached over $1 billion in market capitalization within its first four months and subsequently achieved a peak circulation exceeding $4.4 billion with more than $2 trillion in cumulative trading volume. This rapid market penetration positions First Digital favorably within the expanding digital assets sector, which attracted $8.4 billion globally in the first half of 2025. The company’s compliance-first operating model with licenses and registrations in key financial centers including Hong Kong, Gibraltar, and the British Virgin Islands provides institutional confidence that distinguishes First Digital from less regulated competitors in the stablecoin sector.

Multi-Jurisdictional Regulatory Framework and Compliance Excellence

First Digital operates through a sophisticated regulatory infrastructure that spans multiple jurisdictions, providing comprehensive compliance coverage for institutional clients. The company maintains licenses through First Digital Trust Limited in Hong Kong under the Trust Ordinance Section 8, while achieving SOC1 Type 2, SOC2 Type 2, and ISO 27001 certifications. This regulatory framework enables First Digital to serve regulated financial institutions and fintech innovators across APAC, UK, and Middle East markets while maintaining the highest standards of security and compliance. The company’s transition to a British Virgin Islands-based issuance structure through FD121 (BVI) Limited demonstrates strategic operational flexibility and positions First Digital for enhanced regulatory compliance across multiple jurisdictions as stablecoin regulations continue to evolve globally.

Institutional-Grade Infrastructure and Operational Capabilities

The company’s technology infrastructure demonstrates significant scalability through FDUSD’s native deployment across multiple blockchain networks including Ethereum, Binance Smart Chain, Sui, and Solana. This multi-chain strategy enhances First Digital’s competitive positioning by providing users with access to ultra-fast transaction speeds, low fees, and high scalability across different blockchain ecosystems. The company maintains institutional-grade custody arrangements with reserves held in segregated accounts through licensed custodian affiliates, supported by independent monthly attestations. This trust framework underpins First Digital’s competitive advantage by providing institutional confidence in FDUSD’s backing and compliance standards, essential for maintaining trading volume and market maker relationships.

Strategic Market Timing and Innovation Focus

First Digital’s December 2025 launch of its Finance District platform positions the company at the forefront of the convergence between artificial intelligence and decentralized finance. This strategic initiative targets the AI economy segment, where AI agents are projected to handle or influence $30 trillion in transactions by 2030 but require programmable, compliant, and reliable settlement infrastructure. The timing aligns with broader industry trends showing accelerated adoption of blockchain technology in financial services, where stablecoin transaction volumes are approaching levels comparable to traditional payment networks. This positioning places First Digital within a rapidly evolving landscape where blockchain technology is gaining recognition as serious financial infrastructure.

Strong Financial Foundation and Growth Trajectory

First Digital expects to report approximately $80-90 million in unaudited revenue for 2025, demonstrating substantial operational scale during a period of rapid growth in stablecoin adoption. The company’s funding history reflects progressive institutional confidence, having raised $25.2 million across multiple investment rounds from notable venture capital firms specializing in digital assets including Arcane Group, Hack VC, Kenetic Capital, and Nogle. The proposed merger with CSLM Digital Asset Acquisition Corp III represents a transformational pathway to public market access and enhanced capital availability for scaling operations. This financial foundation supports First Digital’s ability to invest in technology infrastructure, regulatory compliance, and market expansion while maintaining the reserves and operational capabilities necessary to support its growing stablecoin ecosystem.

Established Advisory Board and Industry Relationships

First Digital has assembled a world-class advisory board comprising distinguished leaders from blockchain technology, institutional finance, and digital payments sectors. The board includes industry figures such as Sandy Peng (Co-Founder of Scroll), Luc Froehlich (Chief Commercial Officer at RAK Digital Assets Oasis), Chris Harmse (Co-Founder and Chief Business Officer at BVNK), Praful Morar (Former Chief Strategy & Expansion Officer at Nuvei), and Neil Tan (Former Chairman of the FinTech Association Hong Kong). This collective expertise spanning DeFi infrastructure, traditional finance, stablecoin infrastructure, and regulatory compliance provides strategic guidance that accelerates First Digital’s growth initiatives while maintaining institutional-grade standards.

10) Potential Risk Areas for Further Diligence

Regulatory and Compliance Risk

First Digital operates in a rapidly evolving regulatory landscape across multiple jurisdictions including Hong Kong, Gibraltar, and the British Virgin Islands. The stablecoin sector faces increasing regulatory scrutiny globally, with new frameworks potentially impacting cross-border operations. The company’s transition of FDUSD issuance to a BVI-based structure in August 2025 demonstrates operational flexibility but also highlights ongoing regulatory adaptation requirements. Given the proposed SPAC merger with CSLM Digital Asset Acquisition Corp III targeting U.S. public market listing, First Digital will need to navigate additional SEC compliance requirements and U.S. regulatory oversight.

Reputational and Legal Risk

The April 2025 public dispute with Justin Sun regarding TrueUSD reserve management created significant reputational challenges and market volatility for First Digital’s FDUSD stablecoin. Despite the company’s successful defense of its position and initiation of defamation proceedings, the incident demonstrates vulnerability to high-profile public attacks that can rapidly impact market confidence. The ongoing defamation lawsuit in Hong Kong High Court represents continued legal exposure and potential distraction from core business operations. Market participants’ ability to rapidly destabilize stablecoin pricing through public allegations poses ongoing reputational risk requiring robust crisis management protocols.

Operational Technology and Cybersecurity Risk

As a digital asset infrastructure provider, First Digital faces inherent cybersecurity risks common to financial technology companies. The company operates across multiple blockchain networks including Ethereum, Binance Smart Chain, Sui, and Solana, creating complex technical dependencies and potential points of failure. While the company maintains SOC1 Type 2, SOC2 Type 2, and ISO 27001 certifications, the rapidly evolving nature of blockchain technology and increasing sophistication of cyber threats require continuous security investment. The multi-chain architecture, while providing operational flexibility, also expands the attack surface and requires specialized expertise to maintain security across diverse blockchain ecosystems.

Key Person Dependency and Organizational Risk

Limited public information about First Digital’s executive leadership structure creates uncertainty about key person dependencies and succession planning. The company’s December 2025 launch of the Finance District platform represents a significant strategic expansion into AI economy infrastructure, requiring specialized technical expertise that may be concentrated among few individuals. Successful scaling of operations while maintaining regulatory compliance across multiple jurisdictions requires deep institutional knowledge that could be vulnerable to key personnel departures. The proposed public market transition through SPAC merger will require enhanced governance structures and management depth appropriate for public company operations.

Market and Liquidity Risk

First Digital’s business model depends heavily on maintaining the stability and liquidity of its FDUSD stablecoin, which achieved peak circulation exceeding $4.4 billion. Market volatility, regulatory changes, or competitive pressure from larger stablecoin issuers could impact demand and circulation. The company’s ability to maintain adequate reserves and honor redemption requests during stress periods represents operational risk, particularly given the interconnected nature of digital asset markets. Concentration of FDUSD usage among specific blockchain ecosystems or geographic regions could create vulnerability to market disruptions affecting those segments.

Digital Infrastructure and Third-Party Risk

First Digital’s operations rely heavily on third-party service providers including custodians, blockchain networks, and technology vendors. The company holds FDUSD reserves through qualified custodians, creating dependency on these entities’ operational reliability and financial stability. Smart contract risks across multiple blockchain platforms require ongoing monitoring and potential upgrading as underlying networks evolve. The December 2025 launch of Finance District platform targeting AI economy applications introduces new technical complexities and dependencies on emerging technologies that may carry unproven operational risks.

Financial Transparency and Governance Risk

As a private company preparing for public market entry, First Digital faces enhanced scrutiny regarding financial transparency and corporate governance practices. The company expects approximately $80-90 million in unaudited 2025 revenue, but limited public financial disclosure creates uncertainty about underlying business metrics and sustainability. The proposed SPAC transaction structure, while providing public market access, also introduces additional complexity and potential conflicts of interest requiring careful management. Monthly attestation reports for reserve backing provide transparency but may not fully address investor concerns about financial controls and governance practices appropriate for public company status.

Competitive and Strategic Risk

The stablecoin market faces increasing competition from both established financial institutions and technology companies developing digital payment solutions. Major technology platforms and traditional financial institutions entering the digital currency space could potentially disrupt First Digital’s market position through superior resources and distribution capabilities. The company’s strategic expansion into AI economy infrastructure through Finance District represents significant execution risk in an emerging market with unproven demand and uncertain competitive dynamics.

Cross-Border Operational Risk

First Digital’s multi-jurisdictional structure across Hong Kong, Gibraltar, and the British Virgin Islands creates operational complexity and potential regulatory conflicts. Changes in international sanctions regimes, cross-border payment regulations, or diplomatic tensions between jurisdictions could impact the company’s ability to operate seamlessly across its current geographic footprint. Currency fluctuations and varying regulatory requirements across jurisdictions require sophisticated compliance and risk management capabilities that may be challenging to maintain as the business scales.

Emerging Technology and AI Integration Risk

The December 2025 launch of Finance District platform targeting AI economy applications represents First Digital’s entry into an emerging technology sector with unproven business models and uncertain regulatory treatment. AI-powered payment systems and financial services face evolving regulatory scrutiny regarding algorithmic accountability, data privacy, and consumer protection. The intersection of artificial intelligence and financial services creates novel risk categories that traditional risk management frameworks may not adequately address, requiring development of new monitoring and control mechanisms.

Sources

Save as PDF