What we found
We counted every time USDT's issuer froze, released or burned a wallet on Ethereum from 1 May to 31 October 2026, straight from the USDT contract's own events. This is a full count, not a sample.
- 54 wallets frozen in October, none released. All 54 were still frozen at the end of the month. No wallet was released in September either.
- About $3m burned in October, mostly from older freezes. 17 burns destroyed $3.03m. 14 of the 17 burned wallets had been frozen before May. Over six months, 69 of 81 burns hit wallets frozen before May: burning trails freezing by months.
- One evening made October's total. Three wallets frozen within 17 minutes on 29 October (21:01–21:18 UTC) held $1,176.1m when they were frozen: 96.9% of the balance frozen in October, and one wallet alone 80.0%. Leave those three out and October's other 51 freezes held $37.5m — still the highest of the six months (September $24.0m, the other months $2.6–7.0m).
- A frozen wallet can still receive. October's 54 frozen wallets held $1,213.7m when they were frozen and $1,418.4m at the end of the month: $204.7m more, paid into 10 of them after the freeze.
- Six months: steady, not a spike. 278 different wallets frozen, between 37 and 55 a month (about 46 on average). 59 released, 52 of them in May. 81 burns, $31.6m in total. 58 wallets, about 1 in 5, were already empty when they were frozen.
The frozen and burned totals are never set against each other as a ratio. Most burns hit wallets frozen before May, so the two figures cover different wallets and different times.
How a USDT freeze works
The USDT contract on Ethereum keeps a blacklist that only the issuer can change. Every change is recorded on-chain as one of three events, which is what we counted.
- Freeze (AddedBlackList). The wallet is added to the blacklist. From then on the contract refuses any transfer in which the frozen wallet is the sender. Nothing stops other wallets sending USDT to it.
- Release (RemovedBlackList). The wallet is taken off the blacklist and can send again.
- Burn (DestroyedBlackFunds). Only possible on a frozen wallet: its whole USDT balance is destroyed and the supply falls by the same amount.
That a freeze blocks sending but not receiving is our reading of the contract code; October's data bears it out, with $204.7m arriving in frozen wallets after the freeze. What happens to the value after a burn is not recorded in these three events.
Month by month
Every freeze, release and burn event on the USDT contract on Ethereum, by calendar month (UTC). Values are in USDT, read as US dollars.
| Month | Wallets frozen | Released | Burns | Burned | Held by newly frozen wallets at the freeze | Already empty at the freeze |
|---|---|---|---|---|---|---|
| May | 37 | 52 | 3 | $11.06m | $6.95m | 7 |
| June | 55 | 2 | 23 | $8.50m | $4.82m | 10 |
| July | 48 | 2 | 15 | $4.77m | $6.39m | 3 |
| August | 47 | 3 | 16 | $2.19m | $2.60m | 20 |
| September | 37 | 0 | 7 | $2.09m | $24.01m (one wallet $11.8m) | 6 |
| October | 54 | 0 | 17 | $3.03m | $1,213.66m (three wallets $1,176.1m) | 12 |
| Six months | 278 (all different wallets) | 59 | 81 | $31.64m | $1,258.4m | 58 (21%) |
Released and Burns count the events in each month, whatever month the wallet was frozen in; most of them concern wallets frozen before May. The balance column is the USDT held by that month's newly frozen wallets at the block of their freeze.
How much the frozen wallets held
Balance of each newly frozen wallet at the block of its freeze, grouped by size.
| Balance at the freeze | October | May to October |
|---|---|---|
| Empty | 12 | 58 |
| Under $1,000 | 5 | 26 |
| $1,000 – $100,000 | 10 | 112 |
| $100,000 – $1m | 11 | 58 |
| $1m or more | 16 | 24 |
| Total | 54 | 278 |
What it means for a baht stablecoin
The Bank of Thailand's consultation on a THB stablecoin (public hearing 19–28 October 2026) proposes that coins move only between wallets that have passed KYC, and that the issuer be able to freeze, seize or burn coins used against the conditions. These are proposed principles, not rules in force. USDT shows what running those powers looks like in practice. The points below are ComplyWise's reading, not statements by the Bank of Thailand.
- The button is the easy part. Freezing is routine — about 46 wallets a month on Ethereum alone. Releasing is rare and comes in bursts (52 of 59 in one month). Burning is slow and small. A Thai issuer needs the decision process written down: who may order a freeze, on what basis, and how fast it must happen.
- Money keeps arriving after a freeze. A freeze that blocks only sending leaves the wallet open to new money, as October's $204.7m shows. A baht design needs a rule for funds that arrive after the freeze.
- Burn to refund. The path from a burn to a refund for the people who lost money should exist before the first case, not after it.
- Some freezes are pre-emptive. About 1 in 5 frozen wallets held nothing at the time, so freezing is also used to shut an address before money arrives. That calls for clear criteria and a way to challenge a freeze.
- Whitelist versus blacklist. USDT can be held by any address until the issuer blacklists it. The Bank of Thailand's model admits only verified wallets in the first place, which is the stronger control.
What the Bank of Thailand proposes for issuers and wallet providers is set out on our THB stablecoin page.
Method
- Data. Every AddedBlackList (freeze), RemovedBlackList (release) and DestroyedBlackFunds (burn) event emitted by the USDT contract on Ethereum, read through standard node calls (eth_getLogs) on a commercial node service and counted by ComplyWise: 418 events in total. This is our own computation from public records, not a third-party statistic.
- Window. 1 May to 31 October 2026 (UTC). Month boundaries were set by block timestamp. "Six months" means May to October inclusive.
- Balances. Each wallet's USDT balance read at the block of its freeze, and again at the last block of October together with its blacklist status (archive node calls, eth_call). USDT has 6 decimal places on Ethereum; one USDT is read as one US dollar.
- Cross-check. October was pulled a second time from a public block explorer: the same 54 freeze and 17 burn events, with matching amounts.
- Counting. Wallets frozen = freeze events; all 278 were different addresses and none was frozen twice in the window. Burned = the amount in each burn event. A burned wallet with no freeze event inside the window was frozen before May.
Limits
- Ethereum only. USDT also circulates on other chains, including Tron, and freezes there are not counted. These figures are not the issuer's total. Other stablecoins are not covered.
- October is one incident. 97% of the balance frozen in October sits in three wallets frozen on the evening of 29 October. Press reports of 29–30 October tied freezes that evening to a suspected hack of a large exchange. That link is press context, not something the on-chain records show; we have not verified it and name no exchange.
- Why a wallet was frozen is not on-chain. The events record that a freeze, release or burn happened, not the reason. An empty wallet at the freeze may have been frozen pre-emptively or emptied just before; the data cannot tell which.
- Releases come in bursts. 52 of the 59 releases fell in May. The reason is not visible on-chain, and six months is too short to say whether this is typical.
- No ratio of burned to frozen. Burns mostly hit wallets frozen before the window, so the $31.6m burned is not a share of the $1.26bn frozen.
- No identities. We did not try to identify who holds the frozen wallets. No addresses and no names appear in this analysis.
The series
On-chain data is ComplyWise's own reading of public blockchain records: one question per issue, the method in full, the limits stated, and no addresses or names.
Frequently asked questions
- Can a frozen USDT wallet still receive USDT?
- Yes, on Ethereum. The freeze stops the wallet sending, not receiving. October's frozen wallets took in $204.7m after they were frozen.
- Who can freeze USDT?
- Only USDT's issuer, through the blacklist built into the USDT contract. Each freeze, release and burn is recorded on-chain as a public event.
- Does a freeze mean the money is gone?
- No. The balance stays in the wallet until the issuer releases or burns it. Over six months on Ethereum, 59 wallets were released and 81 burns destroyed $31.6m.
- Is $1.2bn frozen in a month normal?
- No. 97% of October's figure sits in three wallets frozen on one evening. The other 51 October freezes held $37.5m, which is still the highest of the six months.
- Would a baht stablecoin work the same way?
- Not necessarily. The Bank of Thailand proposes that coins move only between verified wallets and that the issuer be able to freeze, seize or burn. These are proposed principles from a consultation, not rules in force, and the detailed process is not yet set.
Sources
- ethereum.org — JSON-RPC API, eth_getLogs and eth_call (the node calls used to read freeze, release and burn events and wallet balances)
- BOT — Public hearing on principles for supervising businesses related to THB stablecoin (19–28 Oct 2026) (Thai)
- BOT consultation paper: principles for supervising businesses related to THB stablecoin, with annex on selection and supervision criteria (October 2026) (Thai, PDF)
Accessed and last reviewed . Each figure and table cell is traced to a source above.