Spiko (EUTBL / USTBL)

REJECTED ON UNVERIFIED US-PERSON ACCESS, NOT ON FUND QUALITY. Spiko runs two genuine UCITS-compliant money-market sub-funds (EUTBL, USTBL) inside the AMF-authorized Spiko SICAV (registry SCV20240012, authorized 2024-04-05), managed by Twenty First Capital under an existing AMF license (GP-11000029). That is a real EU retail-fund regime, not a Reg D private placement, and its on-chain control model — a permission-managed contract with a super-admin multisig, allowlist gating, and a pause function — is disclosed at the engineering level. But this is a French, AMF-regulated retail fund, and its own Terms of Use reserve ”the right to refuse access… to residents of countries not eligible,” which implies a jurisdiction allowlist or blocklist this review could not extract from the published PDF. EU retail funds routinely exclude US persons entirely to avoid US securities and tax-registration entanglements (PFIC treatment for a US taxpayer holding a foreign fund is a live problem even where technically permitted). This registry serves US mass-affluent clients, and every comparable tokenized-fund entry in this backlog that explicitly excludes US persons — Ondo Global Markets, Anemoy/JTRSY, and previously BUIDL and USYC — is rejected on that access ground rather than assumed accessible. Spiko gets the same treatment until its eligibility rules are confirmed to cover this client population.

Review triggers: events that reopen the verdict
• Spiko’s eligibility rules or onboarding flow confirm US persons in this registry’s target client population may subscribe and redeem
• The jurisdiction allowlist/blocklist referenced in the Terms of Use is disclosed in full
• The daily-cutoff redemption mechanic is shown to hold up under a real subscription/redemption stress event without a suspension
• Any AMF enforcement action or fund NAV impairment, which would independently reopen this file toward a harder rejection

Watched nightly: a warning on its venues or files, or a cited document that changes, reopens the memo. The first confirmation is due 2026-11-17.

The research file

Mechanism and fund structure

Spiko is a French fintech, founded June 2023, operating two UCITS-compliant, variable-NAV money market sub-funds inside the Spiko SICAV: EUTBL (short Eurozone government T-bills) and USTBL (100% US Treasury bills, T-bill-secured repo, and cash). Tokens are on-chain representations of fund shares, deployed across Stellar (the majority of activity), Ethereum, Arbitrum, Base, Polygon, Starknet, and Etherlink. The SICAV was authorized by the AMF on 2024-04-05 under registry SCV20240012, with Twenty First Capital, an AMF-licensed management company since 2011, as manager. This is a genuinely regulated retail fund vehicle, not a synthetic wrapper or an unregistered note.

Eligibility and the unresolved access question

Spiko markets tokens as ownable by ”any type of investor (including retail investors),” but only after KYC/AML onboarding — the tech blog describes the system as ”public-permissioned,” with only allowlisted addresses able to hold or receive tokens. The published Terms of Use (v2.1, updated 2026-01-13) state Spiko ”reserves the right to refuse access… to residents of countries not eligible,” which implies a jurisdiction gate, but the specific excluded-country list could not be extracted from the PDF in this review. This is the load-bearing open question: an EU UCITS retail fund excluding US persons is the normal case, and until Spiko’s own onboarding flow or terms confirm otherwise, this registry cannot assume its US mass-affluent client base can actually subscribe.

On-chain control

Spiko’s own engineering writeup describes a Permission Manager contract with seven roles: a super-admin multisig with full upgrade and permission control, an exceptional-operator that can pause the token contract, a daily-operator for mint and redeem, an oracle-operator for NAV publication, a burner, an allowlister, and the allowlisted addresses themselves. Contracts use OpenZeppelin’s UUPS upgradeable-proxy pattern, so the super-admin multisig can change contract logic. Non-allowlisted transfers revert. This is a standard permissioned RWA design comparable to Securitize’s DS Protocol, and it is disclosed in enough detail to evaluate — the gap is jurisdictional eligibility, not contract-level opacity.

Redemption and the liquidity-mismatch flag

Subscriptions and redemptions cut off at 10:30am CET and execute at the last published NAV — forward pricing, not instant atomic settlement — with same-day (T+0) settlement per the fund factsheet. On-chain stablecoin legs settle ”at the speed of the blockchain used” following the fund’s next cutoff, not on demand. The European Central Bank’s own macroprudential analysis flags this as a structural mismatch: token holders may expect 24/7 instant liquidity from an on-chain asset, while the underlying fund can only process at fixed daily cutoffs, a run-risk source if perception and fund capacity diverge. Minimums are otherwise low — €1,000/$1,000 for direct subscription, as little as €1 for Web3-app flows once allowlisted.

Track record and comparison

No depeg, hack, or AMF enforcement action against Spiko was found. AUM grew from a €4M pre-seed (June 2024) past a reported $1B milestone to roughly $2.45B TVL at this review, with a $22M Series A led by Index Ventures (July 2025). Against BlackRock BUIDL and Circle USYC, already rejected in this registry on US-person access grounds, Spiko sits under the same open question rather than a confirmed different answer: a genuinely regulated, retail-eligible EU fund is not automatically a US-client-eligible one. Against Ondo Global Markets and Anemoy/JTRSY, both confirmed excluded to US persons, Spiko has the stronger regulatory pedigree (a licensed UCITS retail fund versus a BVI SPV or BVI-licensed professional fund) but the same unresolved question of whether this specific client population can actually subscribe.

Sources

The claims above trace to these. Where a number could not be independently verified, the thesis says so.

• Spiko — launch of the first tokenized money market funds · primary · accessed 2026-08-17
  Supports: fund mechanism, EUTBL and USTBL composition
• Spiko engineering blog — smart contract architecture · primary · accessed 2026-08-17
  Supports: Permission Manager roles, allowlist and pause design, UUPS upgradeable proxy
• Spiko — Terms of Use · primary · accessed 2026-08-17
  Supports: country-eligibility reservation clause
• Twenty First Capital — Spiko US T-Bills Money Market Fund page · primary · accessed 2026-08-17
  Supports: management company license, settlement timing, minimums
• ECB Macroprudential Bulletin — tokenized money market funds · primary · accessed 2026-08-17
  Supports: on-chain liquidity expectation versus fund cutoff mismatch, run-risk framing
• Crowdfund Insider — Spiko first AMF-licensed tokenized MMF provider · secondary · accessed 2026-08-17
  Supports: AMF authorization, funding history

Inherited controls

The research above describes the protocol layer. Every position also inherits the asset it holds and the chain it settles on. The layer with the most administrative power sets the position’s effective control; that describes control, not quality or suitability.