The CFTC entered the criminal Polymarket case against U.S. Army soldier Gannon Ken Van Dyke on Aug. 24 after a federal judge granted the regulator permission to file an amicus brief.

Van Dyke’s lawyers had opposed the request. They argued that the CFTC was attempting to defend its regulatory authority through the criminal prosecution while its parallel civil lawsuit remained paused.

Judge Margaret Garnett rejected the request to exclude the brief but said the court would give the regulator’s arguments “appropriate weight.” Van Dyke has pleaded not guilty to charges arising from Polymarket wagers that allegedly generated $409,881.

CFTC can defend its Polymarket interpretation

The CFTC requested permission to address Van Dyke’s argument that the Venezuela-related Polymarket contracts were bets rather than swaps regulated under the Commodity Exchange Act.

The regulator argues that event contracts can qualify as swaps when their value depends on events carrying financial, economic or commercial consequences. The Maduro contracts could have related consequences for Venezuelan bonds, oil prices and the country’s currency, according to the CFTC’s civil complaint.

Van Dyke’s attorneys contend that this interpretation stretches the swap definition beyond its statutory limit. They say the contracts were straightforward geopolitical wagers with no underlying financial product or commercial exposure.

“The CFTC is no sheep ‘friend of the Court’ here,” the defense wrote, describing the regulator as a “regulatory wolf.” The language represents legal advocacy, not a court finding.

The defense also disputes whether CFTC Rule 180.1, which prohibits fraud connected with swaps, can support the commodities fraud charge under the circumstances alleged.

Judge gives Van Dyke until September 9

Garnett added the CFTC’s proposed amicus brief to the criminal record. The order does not decide whether the contracts qualify as swaps or whether the disputed charges will survive.

The judge gave prosecutors and Van Dyke until Sept. 9 to answer any CFTC argument not already addressed in their motion-to-dismiss filings. Each optional response may contain no more than 10 pages.

The deadline makes the regulator’s swap interpretation part of the court’s consideration before it rules on dismissal. A decision against the CFTC’s position could narrow how federal commodities law applies to prediction markets.

Van Dyke’s criminal trial remains tentatively scheduled for Dec. 7. A status conference is expected on Sept. 28, although disputes involving classified evidence or the dismissal motion could alter that schedule.

Soldier allegedly earned $409,881 from 13 bets

The Justice Department alleges that Van Dyke participated in planning and executing Operation Absolute Resolve, the U.S. military operation that captured former Venezuelan President Nicolás Maduro on Jan. 3.

According to the federal indictment, Van Dyke placed approximately $33,934 through 13 Polymarket trades between Dec. 27 and Jan. 2. The markets covered Maduro’s removal, U.S. forces entering Venezuela, a potential invasion and presidential war powers.

Prosecutors allege that the trades produced approximately $409,881 in profit after several contracts resolved in Van Dyke’s favor. They also accuse him of transferring proceeds through a foreign cryptocurrency vault and attempting to conceal accounts linked to the activity.

Those allegations remain unproven. Van Dyke faces charges including commodities fraud, wire fraud, misuse and theft of government information, and conducting a monetary transaction involving allegedly criminal proceeds.

Civil Polymarket case remains paused

The CFTC brought a parallel civil action on April 23, its first insider trading case involving prediction-market event contracts. The regulator is seeking restitution, disgorgement, financial penalties, trading bans and an injunction.

The agency’s complaint invokes the “Eddie Murphy Rule,” which prohibits certain uses of misappropriated government information when trading swaps.

A federal judge has paused the parallel CFTC lawsuit until the criminal proceeding ends. Van Dyke’s lawyers argue that the regulator should defend its legal interpretation in that lawsuit rather than enter the criminal matter.

The dispute reaches beyond one trader. In related coverage, the CFTC has been developing updated federal rules for prediction markets as courts consider whether event contracts fall under federal derivatives law or state gambling regimes.

Standard Chartered Bank Hong Kong became the first bank to distribute HKDAP on Aug. 24, giving eligible institutional clients and partners access to Hong Kong’s first live regulated local-currency stablecoin.

Anchorpoint Financial issues HKDAP, short for “HKD At Par,” under licence FRS01 from the Hong Kong Monetary Authority. Standard Chartered is Anchorpoint’s largest shareholder and established the company with HKT and Animoca Brands.

Hong Kong granted two stablecoin issuer licences in April, one to Anchorpoint and another to HSBC. That distinction is important: the regulator licensed two issuers, but HSBC had not publicly launched its stablecoin when Standard Chartered announced its distribution service.

Standard Chartered adds a bank channel for HKDAP

Standard Chartered joins HashKey Exchange and OSL as an authorized HKDAP distributor. HashKey and OSL began offering beta access earlier in August, before Standard Chartered became the first conventional bank to join the distribution network.

Eligible clients can use authorized distributors to convert Hong Kong dollars into HKDAP and redeem the tokens for fiat currency. Access remains limited to institutions, corporate customers and professional investors during the current phase.

As previously reported, Anchorpoint launched HKDAP through a phased institutional rollout. HashKey subsequently completed an initial minting and redemption transaction for approved clients.

HKDAP operates on Ethereum and is intended to maintain a value of HK$1 per token. Hong Kong’s Stablecoins Ordinance requires licensed issuers to maintain adequate reserves, segregate those assets and process redemptions at par.

Anchorpoint’s published figures showed 522,000 HKDAP in circulation as of Aug. 19. That limited supply reflects the project’s controlled beta status rather than broad consumer adoption.

HKDAP will target tokenized fund settlement

Standard Chartered plans to introduce subscription and settlement services for tokenized money market funds during the fourth quarter. The bank said it would work with international and Hong Kong asset managers.

A stablecoin can provide the cash side of a tokenized fund transaction on the same blockchain infrastructure used to record the fund units. This can reduce the timing gap between transferring an investment and completing its payment.

Standard Chartered said the service could support faster settlement, but the bank has not named participating managers or disclosed expected transaction volumes.

The project builds on the bank’s existing tokenization work. Standard Chartered already provides infrastructure for China Asset Management Hong Kong’s tokenized money market fund and previously tested tokenized deposit settlement through the HKMA’s Project Ensemble.

The bank will also test HKDAP for transfers between companies within its group. Further proposed applications include cross-border payments, treasury management and transfers outside conventional banking hours.

Those uses remain pilots or planned services. Standard Chartered has not announced a commercial launch date beyond the Q4 target for tokenized fund subscriptions and settlement.

Hong Kong licensed two stablecoin issuers

The HKMA awarded its first licences to Anchorpoint and HSBC on April 10 after receiving 36 applications. The regulator has said it will remain selective when considering further approvals.

Anchorpoint adopted a business-to-business-to-consumer distribution model. Instead of serving every holder directly, it works with regulated banks, exchanges and commercial partners that provide access and fiat conversion.

In related coverage, HashKey became an authorized distributor for institutional HKDAP access. OSL also provides distribution, liquidity and conversion services during the beta period.

The HKMA has warned investors about unrelated tokens using the HKDAP name. Its April warning said tokens carrying HKDAP or HSBC tickers were circulating without connections to the licensed issuers.

Users must therefore verify contract addresses and access the stablecoin through Anchorpoint’s authorized channels.

Independent review raises contract questions

Security researcher Yajin Zhou published an independent review of HKDAP’s Ethereum contract after its beta launch. The analysis questioned elements of its custom approval, upgrade and access-control architecture.

The review claimed some compliance controls did not operate as expected, but the findings were not an HKMA enforcement determination or confirmed exploit.

No theft or loss was identified in the review. Anchorpoint had not published a detailed public response to the findings at the time of writing.

The next measurable developments will be named asset-manager partnerships, actual fund settlement transactions and updated reserve disclosures. Anchorpoint has also said wider access, including a possible retail expansion, may arrive by the end of 2026, subject to market conditions and regulatory requirements.

Strive, the Nasdaq-listed firm known for a corporate Bitcoin treasury program, bought 1,110 Bitcoin for roughly $81.5 million in the week of Aug. 17–Aug. 21, according to a filing with the US Securities and Exchange Commission. The purchases brought its total holdings to 21,356 BTC.

In the same filing, Strive said it paid an average of $73,409 per Bitcoin (including fees and expenses) for the tranche acquired during that period. Cash and cash equivalents increased by $17.1 million to $171.9 million, while its Class A shares outstanding rose by 3.65 million to 79.89 million.

Key takeaways

• Strive added 1,110 BTC between Aug. 17 and Aug. 21, lifting total holdings to 21,356 BTC.
• The company’s average purchase price was $73,409 per BTC (with fees/expenses), versus Bitcoin trading near the $79,000 level on Monday.
• Strive’s latest buying strengthens its position among public corporate Bitcoin holders, moving it into the top tier tracked by BitcoinTreasuries.NET.
• Strive also reported improvements in liquidity (cash up $17.1 million) alongside share growth during the same reporting window.
• Separately, Strive’s SATA preferred shares returned to the company’s $99–$101 target range after trading near $83.30 in late June.

Another tranche adds to Strive’s corporate Bitcoin stack

The latest treasury update underscores how Strive continues to pursue a steady acquisition cadence. The SEC filing details that Strive paid $73,409 per BTC on average for the 1,110 coins purchased between Aug. 17 and Aug. 21.

That average cost was below the approximate $79,000 Bitcoin price level referenced on Monday in the company’s disclosure context, meaning the new buys were made at a discount to the market price at the start of the week. While the filing does not frame the transactions as a hedging strategy, investors generally focus on the relationship between treasury purchase prices and the prevailing spot market as a signal of how aggressively a company is adding during different market regimes.

BitcoinTreasuries.NET ranks Strive among the largest publicly traded corporate holders. Based on that site’s data, Strive moved to the seventh-largest position behind Bullish and ahead of SpaceX.

Why investors track Strive alongside its asset management business

Strive’s corporate treasury is only one part of its broader footprint. The company operates a Bitcoin-focused treasury strategy alongside an asset management business that, according to its own overview page, manages nearly $3 billion across exchange-traded funds and a direct-indexing platform.

The combination matters because it ties the company’s market positioning to both Bitcoin holdings and recurring business activity in capital markets products. For public-market investors, that dual exposure can influence how the equity trades: sentiment about corporate Bitcoin accumulation can amplify interest, while performance expectations for the asset management segment can affect overall valuation.

In addition to Bitcoin, Strive reported holding 505,000 shares of Strategy’s STRC preferred stock valued at $48.6 million as of Aug. 21, reflecting the cross-ecosystem nature of corporate Bitcoin finance. The disclosure also offers a reminder that corporate Bitcoin holders often maintain diversified positions across preferred structures, not just spot-equivalent BTC exposure.

SATA preferred shares return to the $100 target band

Beyond Bitcoin purchases, Strive’s filing and market commentary also draw attention to SATA, the company’s variable-rate perpetual preferred stock. SATA closed at $100.01 on Friday, returning to management’s targeted $99-to-$101 trading range after having fallen as low as $83.30 in late June.

Strive previously narrowed the trading range from $95–$105 to $99–$101 in March. The company also stated that it would not issue SATA through at-the-market or follow-on offerings below $100, a term designed to limit dilution at lower price levels and to support the intended trading band.

The instrument launched in November 2025, initially selling 2 million shares at $80 each for $160 million in gross proceeds. SATA’s structure includes a stated amount and an initial liquidation preference of $100 per share.

Operationally, Strive positions SATA as an income-oriented product, with a variable dividend rate intended to help keep the shares near $100. In April, the firm raised the annualized dividend rate to 13% and began switching from monthly to daily dividend payments starting June 16, per Strive’s SEC filings.

On Monday, SATA performance suggested renewed stability after a period of weakness. That pattern is important for investors who treat preferred shares differently from common stock: preferreds typically attract buyers seeking income characteristics, but their market price still depends on interest-rate mechanics, dividend expectations, and confidence that the issuer will maintain the design guardrails.

Cross-comparison with Strategy’s STRC and its BTC pause

Because SATA is similar to STRC, the variable-rate perpetual preferred stock issued by Strategy, many traders compare their pricing and dividend behavior. Strategy’s STRC was trading near $97 on Monday, below Strategy’s $100 target, while Strategy reported no Bitcoin purchases for the week ended Aug. 23, according to earlier coverage.

That contrast highlights a potential asymmetry in corporate accumulation behavior: Strive continued buying into the Aug. 17–Aug. 21 window, while Strategy’s most recently reported week showed no purchases. Even without making assumptions about future timing, investors typically watch for whether pause periods broaden or remain temporary—especially because accumulation schedules can affect how markets price treasury companies’ future cash flows, dividend capacity, and balance-sheet momentum.

Strive’s SATA returning toward its target band adds another layer to those comparisons. When preferred instruments track toward their $100 reference points, it may reinforce confidence in the issuer’s dividend-setting framework, even as the underlying Bitcoin market fluctuates.

Looking ahead, investors should monitor two things closely: whether Strive’s BTC purchasing pace continues across the next reporting windows, and whether SATA sustains its return to the $99–$101 band as dividend mechanics respond to broader market conditions. The next few filings should also clarify if corporate accumulation and preferred-share stabilization remain aligned—or diverge.

BNB Smart Chain (BSC) activated its Pasteur hard fork on Tuesday, closing bridge verification and validator authorization gaps while introducing a new route intended to fit more transactions into each block. 

In a Tuesday post, BNB Chain confirmed that Pasteur was live on the BSC mainnet. The team said the upgrade strengthens the network’s bridge, staking and governance security while giving blocks more capacity without changing its 450-millisecond block time. 

The upgrade combines three BNB Evolution Proposals. BEP-682 rejects duplicate validator entries during cross-chain light-block verification, while BEP-695 tightens controls involving validator key rotation, slashing and governance voting. Furthermore, BEP-675 changes how specialist builders submit blocks to validators.

The upgrade prevents validators from being counted more than once in bridge approvals, removes authority from old validator keys and blocks restricted addresses from voting, while aiming to fit more transactions into blocks during busy periods. 

Pasteur targets fuller blocks

Under BSC’s previous block-building route, a builder executed transactions before submitting a proposed block, and the validator executed them again before signing it. BNB Chain said the repeated work took time away from builders operating within the network’s 450-millisecond block window, sometimes leaving blocks underfilled. 

BEP-675 allows builders to submit blocks they have already executed. Validators check the proposed block against consensus rules, sign and broadcast it, then complete full execution verification afterward. Builders can also continue using the previous route, under which validators execute transactions before signing. 

Related: BNB Chain pursues legal action after ex-employee’s memecoin launch

In tests conducted on QANet, an internal environment designed to mirror BSC’s geographically distributed validators, the new route increased throughput by about 88%, from 1,237 to 2,324 transactions per second. Average gas used per block rose from 46.35 million to 84.15 million while the block interval and 100-million gas limit remained unchanged. 

BNB Chain cautioned that the figures came from a controlled test workload and were not mainnet measurements. 

Pasteur follows previous upgrades centered on reducing block times. BSC’s Maxwell hard fork reduced its average block time from 1.5 seconds to about 0.8 seconds in June 2025, while BNB Chain said the subsequent Fermi upgrade brought it down to 450 milliseconds. 

Magazine: MiCA cracks down on USDT in Europe… but no one else cares

Blockchain Association asked five U.S. agencies to clarify that customer identification requirements under the GENIUS Act apply to direct issuer relationships, not independent peer-to-peer stablecoin transactions.

The industry group filed its comments by the Aug. 21 deadline and summarized its position on Aug. 24. It supported the proposal’s main approach but requested clearer definitions, less duplicated compliance work and explicit flexibility for digital identity tools.

FinCEN, the Office of the Comptroller of the Currency, Federal Reserve, Federal Deposit Insurance Corporation and National Credit Union Administration jointly proposed the customer identification program in June.

Stablecoin identity checks focus on direct customers

The proposed rule would require a permitted payment stablecoin issuer to establish a written, risk-based customer identification program. The program would form part of the issuer’s wider anti-money laundering and counterterrorist financing controls.

An issuer would generally collect a customer’s name, address, date of birth or formation and identification number before opening an account. It would then use documentary or non-documentary methods to form a reasonable belief that it knows the customer’s identity.

Records containing the identification information would generally remain on file for five years after the account closes. Verification records would remain available for five years after their creation.

As previously reported, U.S. regulators proposed bank-style identification requirements for stablecoin issuers. The proposal follows the GENIUS Act’s decision to treat permitted issuers as financial institutions under the Bank Secrecy Act.

Blockchain Association wants a firm P2P boundary

Blockchain Association agreed that the program should apply when an issuer maintains a direct customer relationship. Examples include issuing, redeeming, converting, repurchasing or providing custody for a payment stablecoin.

The organization said the rule should not reach transactions between users when the issuer does not intermediate, facilitate or approve them.

“They should not extend to downstream, peer-to-peer stablecoin transactions,” the Association argued, although agencies have not finalized that boundary.

The agencies’ proposal largely follows that position. It says simply owning or controlling an issuer’s stablecoin does not establish an account. A transfer involving an issuer only through its smart contract would also generally fall outside the proposed definition.

The proposal calls these interactions secondary-market activity. Examples include transfers from self-hosted wallets, purchases from intermediaries, exchange trades and direct payments to vendors.

The agencies estimated that approximately 99% of stablecoin transaction activity occurs in secondary markets. They acknowledged that issuers have limited ability to obtain identities for people using tokens without interacting with them directly.

Digital identity and duplicate checks remain contested

Blockchain Association also asked regulators to preserve flexibility in how issuers collect and verify information. It specifically supported digital identity tools and interoperable verification technology.

The proposal already permits documentary and non-documentary verification. It asks whether the final text should explicitly address digital identities or verifiable credentials and seeks feedback about their benefits and risks.

The group also requested protection against duplicative compliance obligations. Stablecoin issuers frequently interact with banks, exchanges and other regulated institutions that already conduct customer checks.

Under the proposed rule, an issuer could rely on certain work performed by another federally regulated financial institution. That reliance must be reasonable, governed by a contract and supported by annual certification. The issuer would remain responsible for compliance.

Blockchain Association wants the final rule to clarify how this arrangement works across affiliates, intermediaries and state-regulated entities.

Agencies must now complete the GENIUS Act rules

The public comment period closed Aug. 21. Regulators will now review submissions and may modify the definitions of “account,” “customer” and “digital asset service provider” before issuing a final rule.

The proposal gives issuers 12 months after the final rule’s publication to comply. No final publication date has been announced.

The wider GENIUS Act framework is expected to begin restricting unlicensed payment stablecoin issuance in the U.S. on Jan. 18, 2027. In related coverage, regulators missed the law’s original rulemaking deadline, shortening the preparation period available before the licensing framework begins.

The final customer identification rule must still operate alongside separate proposals covering licensing, reserves, anti-money laundering programs, sanctions compliance and lawful orders. The treatment of direct redemptions, digital credentials and reliance on third parties will determine how much additional work issuers face.

Bernstein has maintained an Outperform rating and $140 price target on Circle Internet Group, implying about 59% upside after CRCL closed Friday at $87.98, as the brokerage expects USDC adoption to support the company even without passage of the CLARITY Act.

Bernstein analysts led by Gautam Chhugani said in an Aug. 24 note that Circle’s next growth cycle does not depend on Congress passing the U.S. crypto market structure bill during the September session.

Circle shares gained more than 5% on Aug. 21 before closing at $87.98, according to Yahoo Finance data. The $140 target would put the stock about 59% above Friday’s closing price, although it remains below Bernstein’s previous $190 target from earlier this year.

Chhugani’s team tied its outlook to several sources of demand, including stablecoin payments, blockchain-based capital markets, tokenized assets and payments made by autonomous software agents.

The analysts also pointed to changes in global liquidity conditions. Bernstein said Bitcoin has benefited from demand for scarce assets while stablecoins have become another destination for dollars as the U.S. Treasury issues more short-term government debt.

USDC supply has started expanding again

After spending almost six months largely flat, USDC supply increased by about $1.7 billion during the past week, according to Bernstein.

The brokerage said USDC has become an important collateral asset across decentralized finance, tokenized equities, prediction markets and perpetual futures tied to real-world assets. Bernstein estimated that Circle’s stablecoin accounts for about 80% of decentralized exchange trading and finance volumes.

Stablecoin activity outside speculative trading is also expanding, according to the firm. Adjusted transaction volume, which Bernstein said excludes bots and high-frequency activity, reached about $11 trillion during 2025 and was running at an annualized pace of roughly $17 trillion through July 2026.

That pace represented an increase of about 60% from a year earlier, according to the brokerage.

Circle has also been expanding the institutional infrastructure through which businesses can use USDC. In July, crypto.news reported Circle received approval from the Office of the Comptroller of the Currency to establish Circle National Trust, a federally supervised national trust bank.

The approval allows the institution to provide digital asset custody services and could eventually place management of reserves backing USDC within the federally regulated entity, according to Circle.

Institutional access has expanded through banks and digital asset infrastructure providers as well. Circle said during its second-quarter results that Standard Chartered had introduced direct USDC minting and redemption access for institutional customers.

A separate July integration also brought USDC settlement through Fireblocks, allowing institutions to manage USDC balances across supported blockchains and route payments into local fiat currencies through Circle Payments Network.

Fireblocks said stablecoins accounted for 69% of transaction volume across its platform during the second quarter, while Circle said its Payments Network reached $14.7 billion in annualized transaction volume at the end of the quarter.

Circle sees agent payments as another USDC market

Machine-to-machine payments form another part of Bernstein’s Circle thesis, with the analysts pointing to USDC’s early lead in payments made through the x402 protocol.

Circle launched Agent Stack in May as infrastructure that allows software agents to hold assets, discover services and make programmable payments.

By the second quarter, Circle said the platform had more than 900 paid services, while 99.3% of x402 agent-payment volume was settling in USDC.

Independent data has also shown heavy USDC use in the category. A Keyrock report covered in May found that AI agents had settled $73 million across 176 million transactions over 12 months, with USDC handling 98.6% of those payments.

Circle has built Agent Wallets, an agent marketplace and nanopayment tools around the same use case. The company said Agent Stack lets developers set spending limits, allowlists and other controls while permitting agents to make USDC transactions without requiring a human to approve each payment.

For Bernstein, adoption of such services could create another source of stablecoin transaction demand outside cryptocurrency trading.

CLARITY Act outcome does not change Bernstein’s Circle thesis

Regulation remains one of the largest variables for Circle because U.S. lawmakers are still negotiating how stablecoin rewards and digital asset market structure should work.

Bernstein said the outcome of the CLARITY Act would not materially change its investment case.

“We believe, this growth cycle is independent of the Clarity Act passing in the September session,” the analysts wrote.

The brokerage said failure to secure Senate support during the expected Sept. 15 vote could prompt the Securities and Exchange Commission and Commodity Futures Trading Commission to take a larger role in providing regulatory guidance.

“We believe, the SEC/CFTC intervention would accelerate if the Senate does not support Clarity in the Sept. 15 vote,” Bernstein said.

Stablecoin rewards remain one of the contested parts of the legislation. Under the scenario outlined by Bernstein, failure of the bill would leave third-party reward programs operating under the existing model.

If the legislation passes, the analysts expect rewards to become more closely tied to customer activity instead of payments simply for holding an idle stablecoin balance.

Bernstein views either structure as workable for USDC.

Its view has remained consistent even as the language around stablecoin incentives has changed. In May, Bernstein backed Circle’s regulatory position after lawmakers advanced language that restricted deposit-like yield on passive stablecoin balances.

At the time, the brokerage said such restrictions could prevent stablecoin issuers from competing mainly by paying higher returns to token holders, reducing pressure on Circle to enter what the analysts described as an interest-rate competition.

Banking groups have since pushed lawmakers to tighten the rules further. Several U.S. banking organizations urged Senate leaders in July to revise provisions dealing with stablecoin rewards, arguing that some structures could still function like interest-bearing accounts.

Circle faces competition as payment infrastructure expands

Bernstein’s bullish call comes as Circle faces increased competition from other regulated stablecoin models.

Open USD has emerged as one challenge because its consortium structure distributes part of the reserve economics to participating companies, creating a different model from Circle’s approach of earning income from the assets backing USDC.

Mizuho downgraded Circle to Underperform in July and cut its target to $50, citing pressure that Open USD could place on Circle’s margins.

Circle President Heath Tarbert later defended the company’s position, arguing that USDC’s liquidity, existing integrations and regulatory infrastructure would be difficult for new competitors to reproduce quickly.

Circle has continued adding payment partners while competition develops. Its agreement with Japan’s JCB, announced in July, includes tests of USDC for corporate treasury transfers before possible use in merchant payments, while separate partnerships with Kakao and Toss are examining stablecoin settlement and programmable payments in South Korea.

USDC also entered BNY’s Digital Asset Custody platform in June, allowing institutional customers to mint, redeem, hold, and transfer the stablecoin through the bank.

Bernstein disclosed that Chhugani holds long positions in several cryptocurrencies and that the brokerage or its affiliates have maintained investment banking or other business relationships with Circle during the past 12 months.