RIADeFiPublished by Ketju Research
Not approved · Tokenized real-world assets

Ketju memo: Spiko SICAV (USTBL, EUTBL, UKTBL, SAFO)

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 Spiko SICAV: every buyer of every sub-fund must certify that it is not a US person, so a US client cannot hold the shares. The prospectus states that buyers “certify, by doing so, that they are not ‘US Persons’,” and must tell Spiko Finance if that changes. Twenty First Capital’s fund page says US citizens may not access the funds. Spiko SICAV is a French UCITS fund company, authorized by the AMF on 2024-04-05 (registry SCV20240012) and managed by Twenty First Capital. Its prospectus dated 1 September 2026 lists four sub-funds: US, EU, and UK Treasury-bill money market funds (USTBL, EUTBL, UKTBL) and the Spiko Amundi Overnight Swap Fund (SAFO), with USD, EUR, and GBP shares that Amundi manages under delegation. Spiko Finance, the distributor and transfer agent, keeps the share register on public blockchains, so a token balance at an allowlisted address is the fund share itself. We could not settle the research on two points. Spiko’s engineering post says only the redemption contract may burn tokens, but the on-chain roles show other addresses in the burner group. Spiko can therefore remove shares from a holder’s address by more than the one route it describes. SAFO earns its return “predominantly, if not entirely” through total return swaps with a bank, and the prospectus says a counterparty default could cost holders some or all of their capital. We have not found who that bank is or how the swap is collateralized in practice.

Review triggers

  • Spiko or Twenty First Capital opens any sub-fund to US persons
  • Spiko names SAFO’s swap counterparty and publishes the swap’s collateral, or the counterparty defaults
  • The burner group on any share contract is reduced to the redemption contract, or Spiko corrects its published description to match the on-chain roles
  • Spiko uses a redemption cap, suspends a NAV, or fails an instant withdrawal
  • The implementation or permission-manager authority of any share contract changes, or a freeze function is added
  • Any AMF enforcement action or NAV impairment

Facts

Verdict
Not approved
Type
Tokenized real-world assets
Chains examined
Stellar, Arbitrum, Ethereum, Polygon, Base, Starknet, Etherlink, Solana
Instruments
USTBL, EUTBL, UKTBL, SAFO, EURSAFO, GBPSAFO
Reviewed
Last confirmed

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