Research summary
Robinhood sells two things called stock tokens, and neither is a share a US advisor’s client can own. The tokens that live in wallets on Robinhood Chain are debt securities issued by Robinhood Assets (Jersey) Limited, an unregulated Jersey company wholly owned by Robinhood Markets, Inc. through Robinhood International, Inc., under a base prospectus dated 25 June 2026 that Liechtenstein’s FMA approved and notified to 29 other EEA states. Each token is a unit of a tracker certificate: the issuer owes the holder the price of a US stock or ETF, backed by shares Alpaca Securities holds for the issuer and pledged to a Swiss security agent. Holders "do not have any direct rights or claims" to the share, no vote, and a claim limited to that series’ collateral. Under the SEC staff statement of January 28, 2026, that is a synthetic tokenized security. The older Classic Stock Tokens in the Robinhood Europe app are thinner still: an OTC derivative contract with Robinhood Europe, UAB, whose token cannot be transferred at all. Both are closed to US persons. The Jersey tokens are not EU-only; Robinhood says they reach more than 120 countries through Robinhood Wallet, with the US, Canada, the United Kingdom and Switzerland restricted. There is no minimum and no allowlist: anyone outside those places can buy on a Robinhood Chain DEX and move the token wallet to wallet. Only the Authorised Participant, today Bitstamp Global Ltd, may create or redeem with the issuer. An ordinary holder can redeem directly only if every Authorised Participant fails or the issuer posts a notice allowing it. The contracts carry more power than the prospectus describes. The prospectus limits destroying tokens to the issuer’s own holdings, redemptions and court-ordered cancellation. The deployed code, read on 2026-09-23, lets one role burn any holder’s balance, even while the token is paused or the holder is blocked. One contract holds the blocklist, the global pause and the code for all 195 tokens, and every one of its ten roles, including the key that can swap that code with no delay, is a single externally owned address. Robinhood Chain itself is rejected in this registry’s chain review. For a US advisor the answer is no: the client may not hold it, it is not the share, and one key can take it back.
Observable review triggers
- Robinhood opens Stock Tokens to US persons, or moves the product to shares held of record for the holder
- Any of the ten roles on AccessControlsRegistry 0xe10b6f6b275de231345c20d14ab812db62151b00 moves behind a multisig or timelock, or ADMIN_BURNER_ROLE is renounced
- ADMIN_BURNER_ROLE burns a holder’s balance, or BLOCKER_ROLE blocks an address, outside the cases the prospectus names
- The beacon implementation changes from 0xb35490d6f9163de4f80d88dc75c3516eb64c5ae2
- The FMA approves the supplement for atomic settlement and USDG collateral, or the issuer permits direct investor redemption by notice
- Securities lending of an underlying begins, or the custodian, broker or security agent changes
- Robinhood Chain passes this registry’s chain review, or the tokens move to another chain
Facts on file
- Research assessment
- Adverse
- Client selection
- Not considered
- Exposure
- tokenized RWA
- Chains examined
- Robinhood Chain
- Instruments
- SPY, NVDA, SPCX, META, GOOGL, QQQ, AAPL, TSLA
- Reviewed
- Next review