# Ketju memo: Spiko Digital Assets Cash and Carry Fund (SPKCC, eurSPKCC)

- URL: https://riadefi.com/rejections/spiko-cash-carry/
- Verdict: Not approved
- Type: Tokenized real-world assets
- Reviewed: 2026-10-18
- Last confirmed: 2026-10-18

## Summary

Ketju does not approve the Spiko Digital Assets Cash and Carry Fund: every buyer must certify it is not a U.S. person under Regulation S, and that definition covers any discretionary account a U.S. adviser holds, even for a foreign client. The prospectus, updated 1 February 2026, calls the fund a French professional specialized fund (fonds professionnel spécialisé, or FPS) “that is not authorized by the French Financial Markets Authority (AMF).” It is a standalone FCP outside the Spiko SICAV, so the SICAV memo’s terms do not apply. Twenty First Capital keeps the register, and the first subscription is at least EUR 100,000.

The fund buys a certificate from Marex that pays the return of an index Marex owns: long spot Bitcoin or Ether, short the nearest CME future, or cash when the futures premium is too thin. The holder’s return therefore depends on Marex paying. Spiko’s fee page lists a 1% note cost that the key information document leaves out, and the manager takes 25% of any return above SOFR or €STR.

We could not settle the research, because the fund documents do not publish the certificate’s terms: whether Marex posts collateral, when it may end the note early, and which Marex entity owes the money. Spiko’s own pages also disagree with the published index rules on which coins the strategy trades.

## Review triggers

- Twenty First Capital opens the fund to U.S. persons or changes the Regulation S definition it applies
- Spiko or Twenty First Capital publishes the Marex certificate’s terms, including collateral, early termination, and the issuing entity
- Marex defaults on or terminates the certificate, or the fund adds a second counterparty
- Compass publishes a methodology that adds coins beyond Bitcoin and Ether, or Spiko corrects its product page
- The fund uses its 10% redemption cap, suspends its NAV, or its net assets fall toward €300,000
- The implementation or permission-manager authority of any share contract changes, the burner group changes, or a freeze function is added
- Any AMF action against the fund, Twenty First Capital, or Spiko Finance

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Published by Ketju Research (https://ketjuresearch.com). Educational analysis only; not legal, tax, compliance, or investment advice.
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