WisdomTree Government Money Market Digital Fund (WTGXX)

Approved for: WTGXX on Ethereum, Stellar. The limits are in the memo below.

This assessment is favorable with conditions. WTGXX is the only issuer/RWA entry in this backlog set up as a registered US mutual fund instead of a private placement. It is a series of WisdomTree Digital Trust, an SEC-registered investment company (CIK 1859001), managed by WisdomTree Digital Management with Voya Investment Management as sub-adviser, and invests in US Treasury obligations while targeting a stable $1.00 NAV. BlackRock BUIDL, Circle USYC, Ondo Global Markets, and Anemoy/JTRSY were all rejected in this registry on access grounds. WTGXX, by contrast, is open to US retail investors through the WisdomTree Prime app with a $1 minimum, same-day 1:00pm ET NAV cutoff, and no shareholder fees. Ethereum and Stellar provide a mirror, not the books of record. The fund’s SEC-registered transfer agent, WisdomTree Transfers, maintains the Official Record and has the contractual right to correct the on-chain Secondary Record when the two conflict. This control protects investors more than a smart-contract-only freeze function. The conditions reflect a young track record since the fund launched in October 2023, incomplete confirmation of state-by-state retail availability, and an unrelated but real 2024 SEC enforcement action against WisdomTree Asset Management for ESG fund mislabeling.

Review triggers: events that reopen the verdict
• Full retail state coverage confirmed to include the intended client population, or a documented state gap that excludes a specific proposed client
• Twelve consecutive months with no NAV break, redemption suspension, or transfer-agent Official Record correction affecting client positions
• Any WisdomTree Digital Trust-specific SEC enforcement action, as opposed to the unrelated 2024 ETF matter
• The equity-exposed SPXUX or another sibling fund is inadvertently included in a client allocation intended for WTGXX

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

What the tracked figure actually represents

DefiLlama’s ”wisdomtree” TVL does not cover just one fund. Roughly 97% ($752M) is WTGXX itself on Ethereum. The remaining ~$24M is spread across eight smaller sibling funds on Stellar, including FLTTX, WTSYX, TIPSX, WTLGX, and notably SPXUX, an S&P 500 tracker fund that is an equity product, not a money-market instrument. This memo and its approval cover only WTGXX, the dominant holding. The smaller sibling funds, especially the equity-exposed SPXUX, fall outside this tokenized-rwa exposure classification and should not be treated as covered by this approval.

Legal structure and books of record

WTGXX’s SEC prospectus (EDGAR filing 000121465923015364) confirms that the fund is a series of WisdomTree Digital Trust, a registered investment company under the Investment Company Act of 1940. That is the same regulatory category as a conventional mutual fund and differs from every Reg D/Reg S private-placement structure already rejected in this registry’s issuer/RWA batch. WisdomTree Transfers, Inc. (formerly Securrency Transfers, acquired and renamed by WisdomTree) is the SEC-registered transfer agent. It maintains the ”Official Record” of share ownership, while blockchain entries form a reconciled ”Secondary Record.” The prospectus states plainly: ”In the event of a conflict between the transaction history on the applicable blockchain and the records maintained by the Transfer Agent, the Transfer Agent shall update the blockchain record as necessary.” This is a correction process, not a discretionary freeze.

Eligibility and control

The minimum investment is $1. US persons over 18 can invest through the WisdomTree Prime retail app, while a separate WisdomTree Connect channel serves institutional users. Retail state coverage grew from 21 states at the 2023 launch to at least 41 states plus New York in a later press release. A current full-50-state count could not be confirmed, however, so access cannot be assumed for a client in an uncovered state. The prospectus reserves standard money-market-fund control rights: involuntary redemption of an account for suspected fraud or unmet KYC requirements, liquidation of below-minimum balances after written notice, and suspension of purchase orders under AML rules. These are conventional fund-administration powers, not an unusual freeze power.

Redemption

The prospectus confirms a same-day NAV cutoff at 1:00pm Eastern for purchases and redemptions, or earlier if a relevant valuation venue closes sooner. There are no shareholder fees, and the management fee is 0.25% of average daily net assets. This process is faster and more predictable than the discretionary or capacity-limited ”near instant” redemption language that this registry found insufficiently disclosed in BUIDL and USYC. WisdomTree has announced plans for 24/7 trading and instant settlement of tokenized fund shares. That is a forward-looking initiative, not the current process, and this memo does not rely on it.

Track record and regulatory context

No WTGXX-specific incident, NAV break, or redemption suspension was found. The fund is young, with a prospectus dated October 2023, and TVL has grown rapidly, reportedly by over 700% since May 2026. This review treats that growth as a signal to monitor, not an incident. WisdomTree Asset Management Inc. (the parent, not the digital-fund entity) paid a $4M SEC penalty in October 2024 for mislabeling the ESG exclusions of three unrelated ETFs. That is a real compliance-culture data point, though not a digital-fund-specific failure. Separately, the SEC granted exemptive relief to the WisdomTree Treasury Money Market Digital Fund in February 2026 and met with WisdomTree’s Crypto Task Force in August 2026. Those events show active regulatory engagement, not enforcement.

Comparison and decision

Franklin Templeton’s BENJI is the other major ’40-Act-registered tokenized money market fund. WTGXX shares its regulatory category, retail access, and same-day redemption, and both differ from Reg D private funds such as BUIDL. Among all entries in this issuer/RWA batch, WTGXX is the first product this review can recommend to this registry’s US mass-affluent client base without an access barrier. The assessment still has real open items: incomplete confirmation of state coverage, a young track record, and an unrelated parent-level enforcement history. None amounts to a structural defect in the fund itself.

Sources

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

• WisdomTree Government Money Market Digital Fund — SEC prospectus · primary · accessed 2026-08-17
  Supports: registered investment company status, Official Record vs Secondary Record, transfer agent conflict-resolution authority, same-day NAV cutoff, minimum investment, fees, involuntary redemption rights
• DefiLlama — WisdomTree protocol data · secondary · accessed 2026-08-17
  Supports: chain and fund TVL breakdown
• WisdomTree Transfer Agency and Services Agreement — SEC filing · primary · accessed 2026-08-17
  Supports: transfer agent identity, agreement terms
• SEC — WisdomTree ESG mislabeling enforcement action · primary · accessed 2026-08-17
  Supports: $4M penalty, unrelated ETF mislabeling, parent-entity compliance history
• Stellar — WisdomTree Prime state availability statement · secondary · accessed 2026-08-17
  Supports: retail state coverage
• eco.com — top tokenized treasury funds comparison · secondary · accessed 2026-08-17
  Supports: ’40 Act registered vs Reg D private placement comparison

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.