KETJU Research

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Tokenized real-world assets

Spiko SICAV (USTBL, EUTBL, UKTBL, SAFO)

Under review The evidence is not yet settled
Issued
2026-09-23
Last confirmed
2026-09-23
Next check due
2027-03-23
Research basis
Individual research
Chains
Stellar · Issuer can freeze, Arbitrum One · Mixed control, Ethereum · No freeze key, Polygon PoS · Mixed control, Base · Mixed control, Starknet · Mixed control, Solana · Governed, no freeze
Symbols
USTBL EUTBL UKTBL SAFO EURSAFO GBPSAFO
Eligibility file
What the holder owns and who may hold it

Spiko SICAV is a French UCITS fund company, authorized by the AMF on 2024-04-05 (registry SCV20240012) and managed by Twenty First Capital. Its prospectus dated 1 September 2026 lists four sub-funds: US, EU, and UK Treasury-bill money market funds (USTBL, EUTBL, UKTBL) and a new one, the Spiko Amundi Overnight Swap Fund (SAFO), with USD, EUR, and GBP shares managed by Amundi under delegation. Spiko Finance, the distributor and transfer agent, keeps the share register on public blockchains, so a token balance at an allowlisted address is the fund share itself. The earlier memo left one question open: whether a US client could subscribe. The prospectus answers it. Every buyer of every sub-fund “certify, by doing so, that they are not ‘US Persons’,” and must tell Spiko Finance if that changes. Twenty First Capital’s fund page says US citizens may not access the funds. We therefore record the model client as ineligible. That was the load-bearing question, and the answer is the one the earlier memo expected. The research assessment stays unresolved, for reasons the new documents raise rather than settle. Spiko’s engineering post says only the redemption contract may burn tokens; the chain shows other addresses in the burner group, so Spiko can take shares out of a holder’s address by more than the one route it describes. SAFO is not a Treasury fund: the prospectus says it is exposed “predominantly, if not entirely” through total return swaps with a bank, and that a counterparty default could cost holders some or all of their capital. This review has not established who that bank is or how the swap is collateralized in practice. The terms also changed in detail: orders for USTBL and EUTBL now close at 11:30 a.m. Paris time, not 10:30 CET, and the minimum is one unit of the share’s currency, not €1,000 or $1,000. None of this matters to a US client who cannot buy; it matters to the research record, which should not claim more than the evidence shows.

The research file

What the holder owns

A USTBL token is a share of the Spiko US T-Bills Money Market Fund (ISIN FR001400ODM9), a short-term variable-NAV money market fund under the EU money market fund rules that holds US Treasury bills and cash. EUTBL (FR001400ODL1) does the same with euro-area bills and UKTBL with UK bills. The shares are accumulating: income raises the NAV rather than paying out. The prospectus makes Spiko Finance the keeper of the register and says it “relies on public Distributed Ledger Technologies (DLT)” to do so, which in the SEC staff’s January 2026 terms is the issuer-direct model: the chain is the record. Shares carry the votes of any SICAV share. There is no SIPC or deposit insurance; the protection is the UCITS rulebook and a depositary.

SAFO is a swap fund, not a bill fund

The Spiko Amundi Overnight Swap Fund holds a basket of bonds, equities, and money market instruments and swaps that basket’s return with a bank for an overnight rate plus a margin: SOFR for the USD share (FR0014015LE1), €STR for the EUR share (FR0014015LD3), and SONIA for the GBP share (FR0014015LF8). The holder earns roughly the overnight rate only while the swap performs. The prospectus is plain about the failure path: because the sub-fund is exposed “predominantly, if not entirely, through Total Return Swap contracts, the realization of this counterparty risk could result in a total or partial loss of the capital invested,” and collateral may not cover it. Collateral must be liquid OECD bonds rated at least BBB-, with haircuts, and received securities may not be reused. SAFO takes orders until 3:00 p.m. Paris time and pays redemptions the next business day. Its management fee is 0.25% a year (0.40% on the D shares) plus up to 0.10% of costs. The earlier memo covered only the bill funds; SAFO sits under the same project and needs its own counterparty read.

Who may buy, and on what terms

Anyone who is not a US person, after Spiko’s identity checks, as an individual with full legal capacity or a legal entity. The share tables set a minimum first and later subscription of one unit of the share’s currency (1 USD, 1 EUR, 1 GBP), open to all investors. The earlier memo’s €1,000/$1,000 direct minimums are not in the current prospectus. A token can move over the counter only to a buyer whose address Spiko has already allowlisted; transfers to any other address revert. The US-person bar is a certification at purchase, backed by the allowlist, so a US client could not lawfully reach the shares by buying from a non-US holder either.

How money gets out

USTBL and EUTBL orders that Spiko Finance clears by 11:30 a.m. Paris time fill at the next NAV, which the investor does not know when ordering; later orders roll to the next business day. Subscriptions and redemptions can settle in USDC or EURC; the prospectus names Circle’s French entity as the issuer of the e-money tokens the sub-funds may hold, which adds Circle as a dependency of the fast exit. Spiko also offers an instant-withdrawal service up to a per-customer limit at the NAV in force. Under stress the management company may cap redemptions once net outflows reach 10% of net assets for USTBL and EUTBL or 25% for SAFO, for at most 20 NAVs in three months; unexecuted orders roll forward and cannot be withdrawn. The ECB’s April 2026 bulletin flagged the gap this creates: a token moves around the clock, but the fund deals once a day and can cap exits.

Who controls the tokens

Each share is an upgradeable ERC-20 on Ethereum and Arbitrum (and on other chains the prospectus lists), governed by a shared permission manager. Spiko’s engineering post describes the groups: a super-admin multisig that can upgrade the contracts and change permissions, an exceptional-operator group that can pause, a daily operator that mints and handles redemptions, an oracle operator that posts the NAV, an allowlister, and a burner role it says belongs only to the redemption contract. The eligibility file reads the deployed contracts: allowlist, pause, burn from a holder’s address, role-gated mint, and upgradeToAndCall, with no freeze function on the token; the burner group holds addresses besides the redemption contract. The powers are ordinary for a fund register, but the published description understates who can burn.

Record and comparison

No depeg, hack, suspension, or AMF enforcement action against Spiko was found. Spiko raised a €4 million pre-seed in June 2024 and a $22 million Series A led by Index Ventures in July 2025, and reported more than $1 billion under management. Against BlackRock BUIDL and Circle USYC, Spiko’s bill funds are retail UCITS funds with a one-unit minimum rather than private funds with six- or seven-figure minimums; against Ondo Global Markets and Anemoy JTRSY, Spiko has the stronger regulator. None of that reaches a US client, whom the prospectus excludes as plainly as USYC’s terms do. For a US client the comparable instrument is a registered government money market fund or a Treasury-bill ETF held at a custodian.

Sources

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

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.

ChainVerdictControlControl constraint
StellarRejected Issuer can freeze freeze is native at every level: issuers hold revocation and clawback flags on their assets, and since Protocol 26 the validator quorum can vote to freeze specific accounts and trustlines on-chain (CAP-77).
Arbitrum OneApproved with limits Mixed control a single sequencer orders >99% of transactions and admin keys can upgrade bridge contracts on a ~7-day timelock.
EthereumApproved No freeze key No sequencer, no upgrade key, no operator who can be compelled. Rule changes require social consensus.
Polygon PoSRejected Mixed control a public validator set orders transactions, but a 5-of-9 multisig can instantly upgrade staking and canonical bridge contracts, while a 5-of-8 controls custom child tokens.
BaseApproved with limits Mixed control Coinbase, one regulated US company, operates the only sequencer, and admin keys can upgrade bridge contracts within ~7 days.
StarknetApproved with limits Mixed control validity proofs and a regular exit window constrain control, but permissioned proposers and an instant emergency Security Council remain live dependencies.
SolanaApproved with limits Governed, no freeze no admin key can seize funds, but stake concentration and a sub-25 Nakamoto coefficient are the standing watch items.
AssetControlWho can freeze it
USTBL Issuer can freeze Spiko US T-Bills Money Market Fund, an AMF-authorized UCITS sub-fund. Not offered to U.S. persons; operators can pause and burn, and the contract is upgradeable by a super-admin multisig.
EUTBL Issuer can freeze Spiko EU T-Bills Money Market Fund, an AMF-authorized UCITS sub-fund holding euro-area bills. Same contract and controls as USTBL.
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