DAI: who controls it?

The control finding

Originally crypto-backed, now substantially backed by real-world assets and USDC held with custodians. Materially less censorship-resistant than it once was.

Named controller

Sky governance (formerly MakerDAO); no token-level blocklist, but reserves include assets that custodians can freeze

Holder’s position

DAI is minted against a collateral mix that was originally crypto-only but now includes real-world assets and USDC. The holder's claim depends on governance-set collateral policy and the solvency of that mixed reserve, not solely on-chain collateral.

Redemption or exit

There is no issuer redemption desk. Holders exit through on-chain liquidity or by repaying a DAI debt position against its collateral.

Dependencies an advisor should record

• Sky governance and collateral policy
• Real-world asset custodians and their compellability
• USDC held as reserve collateral, and Circle's freeze power over it
• On-chain liquidity for the peg
• The chain carrying the position

Why this distinction matters

DAI is materially less censorship-resistant than it once was. A fiduciary file should record the current collateral mix, not the protocol's original crypto-backed design, since the reserve layer is where the real freeze exposure now sits.

On-chain mechanisms coexist with custodians, real-world assets, centralized ordering, or other compellable parties. That finding can coexist with a sound reserve, useful product, or appropriate client role. The grade prevents the on-chain wrapper from being mistaken for the absence of an administrator.

Questions before use

1. Does the exact contract and chain match the instrument reviewed here?
2. Which party can mint, burn, pause, upgrade, block, or redeem?
3. Does the client have direct redemption access or only secondary liquidity?
4. What protocol, bridge, wallet, and custodian dependencies are added?
5. Which event would force review or exit?