The memo
REJECTED ON ACCESS AND ON AN UNDISCLOSED CONTROL STRUCTURE. OpenTrade states plainly that it has "No Retail Users" — investors must be high-net-worth individuals, companies, professional clients, sophisticated investors, or accredited investors "or the equivalent," run through full Kroll KYC/AML/CFT screening. That alone places OpenTrade in the same access-rejected category as BUIDL, USYC, and this batch's other institutional-only RWA products. It is compounded by a genuine disclosure gap this review could not close: no admin, pause, or emergency-control power over the vault contracts is documented anywhere in OpenTrade's public materials, even though the underlying Perimeter Protocol architecture (which OpenTrade forked from Circle Research) documents privileged Pool Admin roles as a standard feature. Named regulated custodians and broker-dealers are also never identified — the docs describe roles generically as "Regulated Custodians" and "Broker/Dealers" without naming firms — and no primary audit report for the vault contracts (versions v2 through v5) could be located despite the docs referencing several. A bankruptcy-remote Cayman SPC wrapper is a genuine structural strength, but it does not substitute for disclosed control mechanics.
What would reopen the file
- A US-eligible offering opens to this registry's target client population
- Admin, pause, and emergency-control powers over the deployed vault contracts are disclosed, including key-holder identity and any timelock
- Named regulated custodians and broker-dealers are disclosed for each product
- A primary audit report for the current vault contract version is published and reviewed
Facts on file
- Verdict
- Rejected
- Exposure
- tokenized RWA
- Chains examined
- Avalanche, Plume Mainnet, Ethereum
- Memo version
- v1
- Reviewed
- Next review