Can my client hold it? Who may hold every tokenized program on file

The answer, counted

Of the 95 tokenized programs Ketju has on file, an ordinary US client who is not accredited may buy 35. Accredited status opens 9 more, and qualified-purchaser status 12 more. 39 are closed to every US person, whatever the client’s wealth. The retail group is smaller than it looks: 2 of its 35 programs ask $1 million or more for a first purchase, and 33 publish no list of the states where they sell. An IRA narrows the list again. 2 programs name IRAs as eligible holders, 4 exclude them in writing, and the other 89 do not say.

Each row below is read from the program’s eligibility file, which quotes the issuer’s documents and dates the reading. The freeze-key column is read from the chain, last read on 2026-09-30. The newest file was reviewed on 2026-09-30.

Every program on file

Jump to: US retail investors 35 US accredited investors 9 US qualified purchasers 12 Not offered to US persons 39

The program name opens its Ketju file, where each term carries the issuer’s words, the document, and the date the words were found. The IRA reading is explained in Tokenized assets in an IRA.

What the four groups mean

The files sort each program by the lowest investor status its issuer’s terms admit. When the words leave it unclear, the file takes the stricter reading.

US retail investors. The issuer admits US investors with no wealth test. That is a floor, not a promise of access. Onboarding still applies, the minimum still applies, and 33 of the 35 programs in this group publish no list of the states where they sell.

US accredited investors. The test is Rule 501(a) of Regulation D. A person qualifies with net worth over $1,000,000, alone or with a spouse or spousal equivalent, with the primary residence left out; or with income over $200,000 in each of the two most recent years, or $300,000 jointly, and a reasonable expectation of the same this year; or by holding a professional credential the SEC has designated. Certain trusts qualify with more than $5,000,000 in assets, and an entity qualifies when all of its equity owners are accredited.¹ Offerings under Rule 506(c) may advertise, and in return “The issuer shall take reasonable steps to verify” that every buyer is accredited, so a checked box is not enough.²

US qualified purchasers. A higher bar, set by the Investment Company Act: a natural person who owns at least $5,000,000 in investments, certain family companies with the same, or anyone who invests at least $25,000,000 on a discretionary basis for itself or other qualified purchasers.³ Private funds use it because section 3(c)(7) keeps a fund outside the Act only while its securities are “owned exclusively by persons who, at the time of acquisition of such securities, are qualified purchasers.”⁴ The fund cannot waive the test for a good client; the exemption depends on it. BlackRock USD Institutional Digital Liquidity Fund (BUIDL and the I Class, BUIDL-I) sits in this group, at a $5 million minimum.

Not offered to US persons. These programs sell only outside the United States, most under Regulation S. Its definition of a US person reaches past residence: it includes “any trust of which any trustee is a U.S. person” and any non-discretionary account “held by a dealer or other fiduciary for the benefit or account of a U.S. person.”⁵ Wealth does not change the answer. An advisor who finds one of these tokens in a US client’s wallet is looking at a holding the issuer’s terms do not allow.

What a transfer allowlist means

An allowlist is a list of wallet addresses that the issuer or its transfer agent keeps. The token contract checks it on every transfer and refuses to move tokens to an address that is not on it. A wallet gets on the list only after onboarding: identity checks, the investor-status test, and signed fund documents. The list is how an issuer enforces the floor in the table. Superstate’s transfer-agency agreement with Exodus, filed with the SEC, states the rule in one sentence: “Superstate shall create, update, and maintain an Allowlist, and ensure that the smart contract(s) underlying the Tokenized Shares is/are programmed such that Tokenized Shares may only be transferred to or held by digital wallet addresses of persons or decentralized exchange pools on the Allowlist.”⁶

Two things follow. First, buying the token from another holder does not make the buyer eligible. BlackRock’s documents for its BRSRV fund say: “Before transferring OnChain Shares, you (as the transferor) and the potential transferee must each have an active, permissioned (i.e., “whitelisted”) wallet registered with the Transfer Agent.”⁷ Second, the wallet is part of the eligibility, not just the investor. Fidelity says of its FDIT fund: “Only wallets that are approved by the transfer agent are authorized to purchase, redeem and hold OnChain class shares of the fund. Investors may not hold their shares in any other wallet.”⁸ For a client’s IRA, the wallet on the list has to be one the IRA’s custodian controls.

Of the 89 programs with a readable contract, 47 gate who may hold on at least one chain. 31 put no allowlist on any contract read, including 15 of the programs closed to US persons, which is how their tokens can reach a US wallet at all. A token that moves freely is not a token anyone may own. PAX Gold is the plainest case: anyone may hold PAXG on chain, but “Only verified Customers may purchase PAXG from us or convert or redeem PAXG from us.”⁹ A holder who is not a Paxos customer can sell PAXG; it cannot redeem it with Paxos.

Reading the other columns

Minimum is the first purchase the issuer’s terms state, in dollars. “Not stated” means the documents read give none. When the figure differs by chain or share class, the file’s notes give each one.

IRAs and other accounts reads the issuer’s documents for retirement accounts: they name IRAs as eligible, exclude them in writing, or do not say. The words in parentheses are the account types the issuer onboards, when its terms list them. Silence is not permission; the IRA page explains why.

Freeze key names the weakest key that can freeze a holder, pause transfers, or claw tokens back, or that holds the admin key that grants those powers. Ketju reads it from the deployed contracts. In 53 of the 89 programs with a readable contract, that key is a single private key. A power is the issuer’s ability, not proof it has been used; it is also how an issuer obeys a court order.

Exit is the first route the file records. Many programs have more, and some routes are open only to the issuer’s own customers.

What to check before a client buys

• The client, or the client’s account, meets the floor in the issuer’s current documents, and the issuer verified it.
• The program is offered in the client’s state, when the file says the issuer has not published a list.
• The minimum for the chain and share class the client will use.
• What the documents say about the account type: IRA, trust, or entity.
• The wallet the issuer will allowlist, and who holds its key.
• Who holds the freeze key, and what the issuer’s terms say about when it is used.
• How the client exits, and whether that route is open to the client or only to the issuer’s customers.

Ketju keeps each program’s eligibility file current, quotes the issuer for every term, and reads the keys from the chain. For the account-type question in depth, read Tokenized assets in an IRA; for what the holder owns, read Tokenized assets for RIAs.