RIADeFi
Not approved · Other

Ketju memo: Spark Liquidity Layer

Not approvedPublished by Ketju Research

This memo sets out what the holder owns, who controls it, how holders could lose money, and whether a position can be sold. The advisor decides any client action and amount. Not investment, legal, tax, or compliance advice.

Summary

Ketju does not approve Spark Liquidity Layer: Spark does not disclose the legal entity that runs it, or who holds its admin, relayer and freezer roles on each of its eight chains. The Liquidity Layer is the system that puts Spark Savings’ sUSDS deposits to work. It routes USDS, sUSDS and USDC to lending markets, ERC-4626 vaults, DEXs and staking venues under Sky governance. About 96% of tracked capital sits on Ethereum mainnet, so the cross-chain gap is today more a governance risk than a large dollar risk. We could not confirm the operating entity’s name or jurisdiction, or any KYC or geographic policy. No source we could reach says whether each of the eight deployments has its own pause authority, or whether Ethereum governance controls all of them through cross-chain messages.

Review triggers

  • Spark publishes the name and incorporation jurisdiction of its operating legal entity
  • Spark publishes who holds admin, relayer and freezer authority on each chain, including whether each deployment has its own local control
  • Spark publishes a KYC and geographic eligibility policy
  • A deployment outside Ethereum grows to material size before Spark discloses its admin structure (Ketju tracks deposits by chain and will review the memo again if this happens)

Facts

Verdict
Not approved
Type
Other
Chains examined
Ethereum, Base, Arbitrum, OP Mainnet, Unichain, Avalanche, Robinhood Chain, X Layer
Reviewed
Last confirmed

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