# Why Ketju rejected Spiko (EUTBL / USTBL)

- URL: https://riadefi.com/rejections/spiko/
- Exposure: tokenized RWA
- Memo version: v1
- Reviewed: 2026-08-17
- Next review: 2026-11-17

## The memo

REJECTED ON UNVERIFIED US-PERSON ACCESS, NOT ON FUND QUALITY. Spiko runs two genuine UCITS-compliant money-market sub-funds (EUTBL, USTBL) inside the AMF-authorized Spiko SICAV (registry SCV20240012, authorized 2024-04-05), managed by Twenty First Capital under an existing AMF license (GP-11000029). That is a real EU retail-fund regime, not a Reg D private placement, and its on-chain control model — a permission-managed contract with a super-admin multisig, allowlist gating, and a pause function — is disclosed at the engineering level. But this is a French, AMF-regulated retail fund, and its own Terms of Use reserve "the right to refuse access... to residents of countries not eligible," which implies a jurisdiction allowlist or blocklist this review could not extract from the published PDF. EU retail funds routinely exclude US persons entirely to avoid US securities and tax-registration entanglements (PFIC treatment for a US taxpayer holding a foreign fund is a live problem even where technically permitted). This registry serves US mass-affluent clients, and every comparable tokenized-fund entry in this backlog that explicitly excludes US persons — Ondo Global Markets, Anemoy/JTRSY, and previously BUIDL and USYC — is rejected on that access ground rather than assumed accessible. Spiko gets the same treatment until its eligibility rules are confirmed to cover this client population.

## What would reopen the file

- Spiko's eligibility rules or onboarding flow confirm US persons in this registry's target client population may subscribe and redeem
- The jurisdiction allowlist/blocklist referenced in the Terms of Use is disclosed in full
- The daily-cutoff redemption mechanic is shown to hold up under a real subscription/redemption stress event without a suspension
- Any AMF enforcement action or fund NAV impairment, which would independently reopen this file toward a harder rejection

---

Published by Ketju Research (https://ketjuresearch.com). Educational analysis only; not legal, tax, compliance, or investment advice.
Machine-readable index: https://riadefi.com/llms.txt · Content API: https://riadefi.com/content.json