Spiko SICAV: US T-Bills, EU T-Bills, and Amundi Overnight Swap Funds (USTBL, EUTBL, SAFO)

This file replaced an earlier record on 2026-09-23. Superseded the same day: the control reading stopped at the token ABI and missed the permission-manager authority every transfer checks, which admits only allowlisted wallets. The file said no allowlist. Same claim model, terms, and exit. Superseded records.

Subscribers see which of their clients hold this program, each household’s answer against these terms, and an alert when the file changes. $49 per advisor per month, first 14 days free.

The verdict is on the memo: Spiko SICAV (USTBL, EUTBL, UKTBL, SAFO) Under review

Who may buy, hold, transfer, and redeem

Each answer rests on the issuer’s own words, quoted from the document named under it. Ketju re-reads each document and records whether the words are still there. Where the documents say nothing, the row says so.

Who may hold it

Anyone who is not a US person; buyers certify this when they subscribe, in each sub-fund.

“Persons wishing to acquire or subscribe for shares in the Sub-Fund certify, by doing so, that they are not ”US Persons”. Any shareholder must promptly notify Spiko Finance if they become a ”US Person”.”

Spiko SICAV prospectus (English), version of 1 September 2026 · US T-Bills and Amundi Overnight Swap Fund sub-funds, Subscription and redemption conditions · words found 2026-09-23

First purchase minimum

One unit of the share’s currency, first and later, open to all investors; the USD shares start at 1 USD.

“1 USD 1 USD All investors”

Spiko SICAV prospectus (English), version of 1 September 2026 · Overview of investment offer, share class tables (minimum initial, minimum subsequent, potential investors) · words found 2026-09-23

Account types

Individuals with full legal capacity and legal entities.

“Customer: a Customer may be a natural person with full legal capacity, or a legal entity acting through one or several natural persons (the Users) and having the power or authorization required to contract in the Customer’s name and on the Customer’s behalf.”

Spiko: Terms of Use · Definitions, Customer · words found 2026-09-23

Who it may be transferred to

Over the counter, only to a buyer whose address is on the allowlist.

“Shares in the Sub-Fund may be transferred by investors in over-the-counter transactions, with terms mutually agreed upon by the seller and the purchaser, provided that the purchaser has an address that has previously undergone Allowlisting.”

Spiko SICAV prospectus (English), version of 1 September 2026 · US T-Bills and Amundi Overnight Swap Fund sub-funds, Transfer conditions · words found 2026-09-23

How a holder redeems

USTBL and EUTBL orders cleared by 11:30 a.m. Paris time fill at the next NAV; later orders go to the next business day.

“Subscription orders, expressed as amounts, and redemption orders, expressed as amounts and numbers of shares, are cleared by Spiko Finance no later than 11:30 a.m. (Paris time). Orders are executed based on the next net asset value (NAV), meaning at an unknown NAV.”

Spiko SICAV prospectus (English), version of 1 September 2026 · US T-Bills sub-fund, Subscription and redemption conditions · words found 2026-09-23

How a holder redeems

SAFO redemptions pay the next business day after the order clears.

“As regards redemptions, settlement takes place on D+1 relative to the centralization day.”

Spiko SICAV prospectus (English), version of 1 September 2026 · Amundi Overnight Swap Fund sub-fund, Subscription and redemption conditions · words found 2026-09-23

Who keeps the official record

Spiko Finance, as transfer agent, keeps the share register on public blockchains.

“Spiko Finance maintains control over the management of the shareholder register. For this purpose, Spiko Finance relies on public Distributed Ledger Technologies (DLT).”

Spiko SICAV prospectus (English), version of 1 September 2026 · Entity responsible for maintaining the register of shareholders on behalf of the Management Company · words found 2026-09-23

What the issuer says it can freeze or take back

Spiko says an emergency group can pause the tokens and only its redemption contract may burn them; the chain shows other addresses in the burner group too.

“The exceptional-operator group can pause and unpause token contracts in case of emergencies. The daily-operator is an in-house relayer responsible for minting tokens to investor addresses and handling redemptions. The oracle-operator is an internal relayer tasked with publishing daily NAV values on-chain. The burner role is assigned to the redemption contract and is the only entity authorized to burn tokens.”

Spiko engineering blog: smart contract architecture · Managing Permissions · words found 2026-09-23

Who can change the record

Powers read from the deployed contracts and their verified source: the token and every contract it consults on transfer. A power recorded here is the issuer’s ability, not evidence it has been used.

Who holds the keys

Every current holder of each power, read from the chain on 2026-09-23. A single key is one private key: whoever holds it acts alone. A multisig needs the stated number of signers. A timelock makes every action wait, so holders can see it coming.

Role holders on Arbitrum, Arbitrum, Arbitrum could not be read from the public event indexes on the last reading; the table shows only what was confirmed.

Where it trades

How it exits

Reopen conditions: events that change an answer above
• Spiko or Twenty First Capital opens any sub-fund to U.S. persons, or changes a minimum subscription
• The implementation or the permission-manager authority of any contract read here changes, or a freeze power is added to the token
• A NAV suspension, a failed instant withdrawal, a default by SAFO’s swap counterparty, or an AMF enforcement action
• The prospectus lists register addresses on Polygon, Base, Etherlink, Starknet, Stellar, and Solana, and for the UK T-Bills fund, the USTBL EUR share, and SAFO’s CHF, D, and Nordic and Central European shares; this file reads the USD, EUR, and GBP shares named here on Ethereum and Arbitrum until those are added
• Spiko uses a redemption cap the prospectus allows: 10% of net assets for USTBL and EUTBL, 25% for SAFO

What the monitor reads daily

Every control function in the table above and the contracts the token consults on transfer; the token’s on-chain supply against yesterday’s; and its market quote against yesterday’s quote, since a fund of this kind accrues a few basis points a day. Every document quoted above is re-read too, and a quote that leaves its document reopens the file. A key that appears, disappears, or changes shape counts as a change only when the chain’s own log shows the grant, revocation, or signer change between yesterday’s block and today’s; a difference the log does not show updates this file’s key list and nothing more. A change opens a review item in the governance queue and reopens the file before any client action. Subscribers get an email naming each of their clients who hold it, with the household result.

File history

Revised 3 times since it was filed. Each superseded copy is kept as published, with the reason it was replaced.

Sources

• Spiko SICAV prospectus (English), version of 1 September 2026 · primary · accessed 2026-09-23
  Supports: four sub-funds, who may hold, minimum, transfer, redemption, redemption cap, record, register addresses
• Spiko Amundi Overnight Swap Fund, USD share: key information document (29 July 2026) · primary · accessed 2026-09-23
  Supports: total return swap, target investors, not marketed to U.S. persons, 3:00 p.m. cutoff
• Spiko docs: Smart Cash fund share classes · primary · accessed 2026-09-23
  Supports: SAFO, eurSAFO, gbpSAFO, chfSAFO symbols, ISIN codes, D+1 liquidity
• Spiko docs: contract addresses and audits · primary · accessed 2026-09-23
  Supports: token contracts per chain, shared permission manager, redemption manager, audits
• Twenty First Capital: Spiko US T-Bills Money Market Fund page · primary · accessed 2026-09-23
  Supports: citizens of the United States are not authorized to access, French SICAV, UCITS, daily valuation
• Spiko: Terms of Use · primary · accessed 2026-09-23
  Supports: access refused to residents of non-eligible countries, MiFID II client categorisation, subscription and redemption in electronic money tokens, instant withdrawal service, account types
• Spiko engineering blog: smart contract architecture · primary · accessed 2026-09-23
  Supports: permission-manager groups, super-admin multisig, pause, burner role, UUPS upgrade, Trail of Bits audit, freeze
• Spiko: launch of the first tokenized money market funds · primary · accessed 2026-08-17
  Supports: AMF authorization, UCITS sub-funds
• Verified USTBL and EUTBL implementation on Ethereum (Sourcify) · primary · accessed 2026-09-23
  Supports: pause, burn from a holder address, role-gated mint, upgradeToAndCall
• Verified SAFO (USD share) implementation on Arbitrum (Sourcify) · primary · accessed 2026-09-23
  Supports: pause, burn from a holder address, role-gated mint, upgradeToAndCall