Centrifuge - Janus Henderson Anemoy Treasury Fund (JTRSY) STEP II Application
To view the recommended PDF version of this application, please see here. The PDF shows updated answers in contrast to previous answers.
Summary Table:
| Change Type | Previous | Updated |
|---|---|---|
| Name | Anemoy Liquid Treausry Fund (LTF) | Janus Henderson Anemoy Treasury Fund (JTRSY) |
| Product AUM | $9,669,838 | $139,005,049 |
| TVL on Arbitrum | $0 | $2,114,000 |
| Legal documentation | PPM + portfolio supplement and subscription agreement sent privately | New PPM + portfolio supplement and new subscription agreement sent privately |
| Fees | Total 15bps annually | Total 25bps annually |
| Liquidity | Standard t+1 banking day redemptions | Standard t+1 banking day redemptions with $100M+ in instant or intraday redemptions available |
| Sub-Investment manager | N/A | Janus Henderson Investors |
| Sub-Advisor | None | Janus Henderson Investors |
| Ratings | None | AA-bf Moodys Rating, AA+f/S1+ S&P Global Rating, Particula A+ rating |
| Portfolio and investment mandate | 0-6 month U.S Treasury Bills | 0-3 month U.S Treasury Bills |
| Composability with other protocols | None | Collateral use-cases within Morpho |
| Other Issued products | None | The Anemoy DeFi Yield Fund (DYF) |
| Legal opinion regarding bankruptcy remoteness | None | Sent to the committee privately |
| Hedging or derivatives permitted? | Not explicitly stated | Explicitly not allowed as stated in the PPM |
Applicant information:
Name: Centrifuge
Address (Headquarters): Grafenauweg 8 (k/f labs)
City, State, Postal Code: Zug, 6300
Country: Switzerland
Website: https://centrifuge.io/
Primary Contact: Grayson Alto
Title: DeFi BD
Country: United States
Email, Telegram, Forum, & other methods of contact:
Telegram: @graysonalto
Email: grayson@k-f.co
Forum: @graysonalto
Key Information
Expected Yield: Janus Henderson Anemoy Treasury Fund (JTRSY) targets returns from the short-end of the Treasury Bill curve at 0-3 months in duration. The three-month rate as of March 17th, 2025 is 4.3%.
Expected Maturity: The fund consists of rolling maturities. The current weighted average maturity (WAM) is 46 days.
Underlying asset: Short-duration U.S Treasury Bills
Minimum/Maximum transaction size: 500,000 USDC/USD minimum.
Current AUM for project: Centrifuge - $225,860,531
Current AUM for issuer: Anemoy – $139,005,049
Volume of transactions LTM: Anemoy - $138,558,234.92
Source of first-loss capital: N/A
Basics and Background
Centrifuge was one of the first RWA protocols to support Arbitrum’s mission of supporting every corner of DeFi, including real-world assets.
Arbitrum Network Support From Day 1
In September of 2023, we launched Liquidity Pools on Arbitrum allowing investors to access Centrifuge pools directly from the Arbitrum network. Centrifuge has since been developing the ecosystem and demand for RWAs on Arbitrum, starting with a webinar with Offchain Labs co-founder Steven Goldfeder in November sharing the vision for bringing RWAs to Arbitrum. Centrifuge is fully operational on Arbitrum and ready to accept investments from day one. Centrifuge is multi-chain by design, all of the liquidity and TVL will stay on Arbitrum.
Today, there is $2,114,000 of JTRSY on Arbitrum despite not being a part of the STEP I allocation, a testament to our commitment to Arbitrum.
Decentralization Is Our DNA
Centrifuge itself is a fully decentralized DAO, and comes with an active ecosystem and contributors. A partnership in this capacity would further the network effects of our relationship by connecting both ecosystems. The Centrifuge ecosystem consists of issuers and liquidity providers, which the Arbitrum ecosystem can onboard at any time.
TVL On The Most Trusted RWA Protocol
An investment through Centrifuge’s platform will bolster RWAs on Arbitrum by bootstrapping network liquidity for one of the largest RWA protocols onchain. The Stable Treasury Endowment Program was set up not only to improve treasury health, but to strengthen projects built on Arbitrum. Using Centrifuge will grow RWA TVL on the Arbitrum network on the most well-recognized RWA protocol. Bootstrapping liquidity on Arbitrum would also further the case for building DeFi primitives composable with our permissioned tokens on the Arbitrum network itself.
Start With Treasury Bills, Expand Beyond
Centrifuge is asset agnostic, meaning we do, and will continue to support diversified, high-quality RWA credit asset managers and issuers. As Arbitrum develops beyond phase-1 in the STEP program, Centrifuge will be able to play a key role as a one-stop solution for onchain credit. By onboarding Centrifuge, the path to other assets becomes a more seamless journey.
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Identify key management personnel and individual experience. Also, include third parties utilized for managing assets and their qualifications.
The Janus Henderson Anemoy Treasury Fund mandate is transparent and clear: to hold a diversified, stable mix of T-Bills with maturities between 0-e months. All fund portfolio management is handled within the Janus Henderson team.
All third-party service provider details are listed later in the application. A summary of the most relevant:
- Custodian of T-Bills: Pershing
- Primer Broker: StoneX
- Banking: First Citizens Bank
- Fund Admin: Trident Trust
- Fund Auditor: MHA Caymans
- Oracle Provider: Chronicle
Core Team:
Bhaji Illuminati
Centrifuge CEO
- Visionary growth leader with a proven track record of scaling transformative tech companies into market-leading brands
- Co-creator of the Real-World Asset Summit and Tokenized Asset Coalition
Martin Quensel
Anemoy & Centrifuge Co-founder
- Serial entrepreneur with 30 years in the software industry
- Founder, advisor, and angel investor
- Co-founded the Fintech Taulia before Centrifuge, which revolutionized supply chain finance and was acquired by SAP
- Co-founder of Centrifuge and Anemoy.
Anil Sood
Anemoy Co-founder, Centrifuge Head of Strategy
- ETF, Capital markets & Asset Management leader with 20 years experience
- Anil has helped to build and run several Institutional cross-asset ETF Market Making franchises including Knight Capital, as part of the listed Derivatives group & was also a partner at Cantor Fitzgerald
- Anil Previously held roles at HANetf, Goldman Sachs, and Barcap.
Eli Cohen
Centrifuge GC & Anemoy Chief Compliance Officer
- Corporate lawyer with over 25 years of experience in commercial transactions, financial services, and regulatory matters
- Worked in Asia, Europe, and the US with companies such as the CME, Euroclear Bank, and SGX
- In crypto since 2019. Previously with Block.One in Hong Kong.
Jeroen Offerijns
Centrifuge CTO
- Experienced engineering & product leader, with 10+ years of software development experience and co-founder of several startups
- Co-author of ERC-7540, the asynchronous tokenized vault standard for RWAs
Key Janus Henderson Investors Team Members:
Ali Dibadj
Chief Executive Officer, Janus Henderson Investors
- Ali Dibadj is the Chief Executive Officer of Janus Henderson Investors and has been an executive director of Janus Henderson since June 2022
- Ali leads the firm’s Executive Committee and is responsible for the strategic direction and overall day-to-day management of Janus Henderson.
Nick Cherney, CFA
Head of Innovation, Janus Henderson Investors
- Helps the firm and its clients to identify, understand, and execute on longer horizon developments that potentially disrupt the way business is managed, and clients manage their investments
- Leads exchange traded funds (ETF) business also
- Portfolio manager at Barclays Global Investors managing over US$25 billion of ETF assets before.
Jim Cielinski, CFA
Global Head of Fixed Income, Janus Henderson Investors
- Leading Fixed Income since 2017
- Oversees all of the global fixed-income products and teams
- Leads Corporate Credit as well
- Previously, Jim was the global head of fixed income for Columbia Threadneedle Investments from 2010.
Michael John (MJ) Lytle
Chief Executive Officer, Janus Henderson Tabula
- Joined Tabula 2018 and brings over 30 years of financial industry experience
- Previously founding partner in Source, an investment manager focused on the creation and distribution of ETFs, including a partnership with PIMCO to create and distribute a range of fixed income ETFs, and purchased by Invesco in 2017
- Prior to Source, MJ spent 18 years at Morgan Stanley with a variety of roles across corporate finance, capital markets origination, trading, sales, equity, fixed income, private wealth and technology strategy.
Rhys Petheram
Chief Investment Officer, Janus Henderson Tabula
- Joined Tabula in 2024 and brings over 20 years of experience in fixed-income and multi-asset investment
- Most recently Head of the Environmental Investment team and as a Fund Manager at Jupiter Asset Management
- Over his 17-year tenure at Jupiter, Rhys managed a range of global credit, government bond and multi-asset portfolios for both retail and institutional investors
- His prior experience includes roles as a fundamental Credit Analyst at Moody’s Investors Service and an Analyst with Towers Perrin in Australia.
Francesco Romano
Head of Risk and Quant, Janus Henderson Tabula
- Joined Tabula in 2020 from GFG S.A.M., where he worked on quantitative strategies and UCITS fund risk reporting
- Prior to this Francesco spent three years at UniCredit Group working on Counterparty Credit and Market Risk
- Francesco holds an MSc in mathematics from the University of Milan.
Andy Baker
Head of ETF Capital Markets & Portfolio Manager, Janus Henderson Tabula
- Joined Tabula in 2018 as Operations Manager
- Previously spent four years at Morgan Stanley across a range of middle office roles including equity swaps, CDS single name, CDS indices, credit options and structured credit products
- Andy has a BSc in economics and management from Brunel University.
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Describe any previous work by the entity or its officers/key contributors similar to that requested. References are encouraged.
Centrifuge is a decentralized RWA protocol with $685M worth of assets financed as of 3/17/2025. Some relevant partners to Arbitrum include MakerDAO, BlockTower, Aave, Frax, Morpho, Plume, and others. Centrifuge is happy to facilitate introductions between organizations as requested. Brief descriptions of our work below:
MakerDAO/Sky:
In the summer of 2022 we proposed alongside institutional lender, BlockTower, to launch a $220M securitization pool on Centrifuge. The BlockTower arrangement was the first time a credit fund’s operations had been brought onchain, requiring immense legal and operational work to bring to fruition. Much of our DAO protocol work since has taken learnings and structures from this arrangement to implement elsewhere.
Centrifuge is excited to also share it’s position in being a winner of the premier Spark Tokenization Grand Prix, a RFP deciding the allocation of Sky’s T-bill allocation, which historically ranges from ~$300M-$4B in value. This is a large milestone in continuing the work of Centrifuge with Sky, and cements Anemoy’s position with DeFi as a RWA issuer.
Aave:
The Centrifuge RWA Market on Aave was launched in 2021 marking the first institutional grade RWA lending market. This allowed users to deposit stablecoins in return for senior or junior tranches of credit directly within the Aave application. Centrifuge continues to work with Aave as they focus on RWA use-cases within lending.
Celo:
Celo is another network using Anemoy on the Centrifuge platform to better their long-term sustainability for their treasury. They invest in JTRSY and have intentions to diversify into other assets including Flow Carbon’s offset pool. Centrifuge is live on Celo through Liquidity Pools, marking the first use case of our multi-chain product. TVL remains on the Celo network, akin to this proposal with Arbitrum.
GnosisDAO:
Some of our newest clients include GnosisDAO, who decided to allocate a portion of their treasury to Centrifuge Prime, mainly the Anemoy Liquid Treasury Fund. The GnosisDAO proposal includes $10M being allocated. Karpatkey is the financial service provider for GnosisDAO who is now managing the day to day operations of all investments including in RWAs.
Frax:
Frax is another DAO that has recently partnered with Centrifuge, Anemoy, and Janus Henderson to allow frxUSD to be backed by JTRSY via DAO governance. This comes off the back of Frax transition the Frax stablecoin into frxUSD, which can be minted and burned with RWA collateral directly, taking advantage of JTRSY’s operational excellence.
Plume:
Centrifuge recently announced its selection as a strategic partner with Plume Network to advance institutional-grade yield through Nest, its flagship staking protocol. As one of Plume’s inaugural partners, Centrifuge will power Nest’s low-risk treasury vaults with JTRSY. Centrifuge will also be deploying it’s RWAs on the Plume Network, further aligning with the Arbitrum ecosystem with the chain being in the Orbit Chain ecosystem.
Morpho:
JTRSY is also enabled to be used as collateral within Morpho’s markets, being part of both the Steakhouse USDC RWA vault and the Re7 RWA vault. At its height this past summer while DeFi rates were suppressed, the vaults attracted $3.2M in USDC, showing demand for lending against RWAs in market downturns.
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Has your entity or its officers/key contributors been subject to an enforcement action, criminal action, or defaulted on legal or financial obligations? Please describe the circumstances if so.
No.
None.
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Insurance coverages, guarantees, and backstops Name of insurer or guarantor Per incident coverage Aggregate coverage
One-hundred percent of Anemoy assets are held at insured, and in the case of invested assets, in systemically important financial institutions, negating the need for additional insurances that ultimately increase the cost for investors. The underlying holdings of the Anemoy Liquid Treasury Fund are held at licensed US banks covered by Federal Deposit Insurance Corporation (FDIC) for cash assets, and the Securities Investor Protection Corporation (SIPC) for securities. The licensed fund administrator, Trident Trust, ensures proper operations of the fund contractually. Insurance such as Directors and Officers (D&O) Insurance is not relevant to the investor because this protects the directors and does not add anything from an investor protection standpoint.
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Historical tracking error in your proposed product, or similar to that being proposed Product 2024 YTD 2023 2022 2021
The Janus Henderson Anemoy Treasury Fund (JTRSY) does not suffer from tracking error as the fund directly holds the underlying assets. These assets, T-Bills, have readily available market prices meaning the NAV is easily calculated by our BVI licensed fund administrator, Trident Trust. A tracking error in this context is the divergence between the price behavior of the JTRSY tokens, and the underlying prices of portfolio assets. This is not applicable for JTRSY tokens as the relationship between NAV and token price is identical. JTRSY tokens do not trade on the secondary market, meaning the only prices come from primary issuance and redemption. The fund NAV is updated daily, and in the case of an issuance/redemption, the NAV is updated at the exact time of such action.
N/A.
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Please describe any experience your firm has in working with decentralized organizational structures
A majority of Centirfuge’s focus since inception, starting with MakerDAO and Aave, has been with decentralized organizations. Question number three above details some of those partnerships.
Centrifuge itself is also a fully decentralized DAO, and believes in decentralization as proven by our actions. The Centrifuge DAO has control over protocol operations. The Centrifuge governance forum can be found here.
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What is your entity’s current assets under management, assets held in trust, total value locked, or equivalent metric for your legal structuring?
Current protocol TVL is $125M. Centrifuge over its lifetime has financed $685M in assets.
Currently, there is $2,114,000 of JTRSY on Arbitrum.
Plan design
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Please describe your proposed product, including a description of the underlying assets and, if more than one asset, the proposed allocation among assets and general investment guidelines. Where appropriate, include targeted maturity mix and credit quality. Attach supplementary documents as appropriate.
The Fund is a fully onchain, actively managed fund designed to offer investors stable income the U.S. Treasuries while maximizing liquidity and safeguarding principal. Focused on U.S. Treasury Bills with maturities of less than three months, the fund is tailored for investors who prioritize capital preservation and predictable returns. Additionally, the Fund seamlessly integrates with decentralized finance, enabling composability within the broader onchain ecosystem.
A key differentiator of The Fund is its distinction as the first tokenized fund to be evaluated by all leading rating agencies, Moody’s Ratings and S&P Global Ratings, alongside the DeFi-native rating agency, Particula. Moody’s assigned a AA-bf rating, Particula a A+, and S&P a AA+f/S1+, the highest ever rating assigned to a tokenized offering.
Janus Henderson Investors as strategic partner and JTRSY Sub-Advisor
In partnership with Janus Henderson Investors (JHI), a global leader in traditional finance managing over $360 billion in assets, the Fund capitalizes on JHI’s exceptional expertise in Fixed Income and Alternatives. As the sub-advisor to the Fund, Janus Henderson Investors will play a central role in ensuring the fund’s success through a comprehensive suite of responsibilities, including:
- Investment Management: Implement and manage the Fund’s investment strategy in alignment with the fund’s objectives, focusing on the selection of appropriate short-term, high-quality debt instruments.
- Portfolio Construction: Build and maintain a diversified portfolio, adhering to the Fund’s guidelines on duration, credit quality, and liquidity, to ensure optimal performance and risk management.
- Research and Analysis: Rigorous credit analysis will be conducted to identify investment opportunities and assess the risks associated with both potential and existing holdings.
- Risk Management: Monitor and manage risks related to interest rates, credit quality, liquidity, and market volatility, ensuring that the fund remains within its prescribed risk parameters.
- Liquidity Management: Active liquidity management will be performed to meet daily redemption requests from investors while maintaining an optimal balance of short-term investments.
- Performance Reporting: Regular performance reports will be provided, including detailed analyses of returns, risk metrics, and comparisons to benchmarks, ensuring transparency and accountability.
- Business Continuity Planning (BCP): Support the fund with structured business continuity planning and its implementation, ensuring operational resilience in any scenario.
JTRSY Built with Centrifuge Transparency
Transparency and Real-Time Access & Comprehensive Activity Tracking:
The Centrifuge app, including the Fund, offers investors unparalleled transparency by providing detailed insights into the individual assets held by the fund. Investors can view their holdings, Fund activities, returns, and overall fund composition in near real-time via the Centrifuge platform. This information is verifiable both onchain and offchain, ensuring complete accuracy and trust.
Partnership with Trident Trust:
Our collaboration with Trident Trust further enhances the accuracy and efficiency of our reporting. Together, we publish an onchain record of portfolio data and net asset valuations, ensuring that all financial records are transparent, up-to-date, and accessible to investors at any time.
Underlying Assets
The Fund will seek to provide a liquid, low risk portfolio through exposure to U.S Treasury Bills (T-bills) with maturities of between 0-3 months. The portfolio is carefully structured to manage yield curve, duration, and liquidity risks.
T-Bills are highly rated short-term debt securities issued by the U.S. Department of the Treasury, with maturities of up to one year. They are widely recognized as one of the safest investment vehicles due to their high credit quality supported by the full faith and credit of the U.S. government. Furthermore, interest rate risk and volatility are low due to the short-term maturity of the instrument.
The fund started with a portfolio T-bills with maturities of between 0-6 months. The portfolio consists of T-bills maturities with a current weighted average maturity (WAM) of 46 days.
JTRSY tokens are the individual shares in The Janus Henderson Anemoy Treasury licensed BVI fund, and come with full legal shareholder recourse rights to the underlying T-Bill and cash assets of the portfolio of the BVI professional fund under BVI law (shares are issued as tokens following BVI law). Tokenholders have the exact same legal rights as shareholders would.
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Describe the legal and contractual structuring for your product including regulatory bodies overseeing your business and the product and identifying all legal jurisdictions interacting with your product. Attach supplementary documents as appropriate.
The Fund is established as a BVI professional fund. This legal structure provides the best possible investor protection of any tokenized treasury product currently available.
The regulatory body overseeing the fund is the The British Virgin Islands Financial Services Commission (FSC).
The BVI professional fund structure provides direct recourse for investors to the segregated and ring-fenced assets of the Fund (i.e., US T-Bills and USD cash) in case of liquidation of the Fund.
Importantly, this direct recourse is enshrined in law rather than a mere contractual right.
This structure is more advantageous for investors than other tokenized treasury products such as SPV/debt offerings or exempt US 3(c)(7) funds.
In the case of products structured as debt offerings issued by an SPV, the investors have no exclusive claim to the assets and will need to prove their claim as against other potential creditors such as tax and other governmental authorities that may have priority. Moreover, as the investors do not have a perfected security interest in the treasuries, the claim may be challenged in court causing an extended timeline for recovery of potentially many years.
In the case of a 3(c)(7) fund, unlike a BVI fund, this is an exempt offering with no oversight by any regulatory authority. Investors’ claims to the underlying assets will be based on contractual terms alone which can be challenged in court leading again to potentially long delays for recovery. Moreover, a US bankruptcy authority would have wide powers including the ability to challenge asset transfers made during a suspect period. This means redemptions from the 3(c)(7) fund occurring up to 90 days prior to bankruptcy can be voided and reversed as the crypto markets have seen occurring with the clawbacks in the Celsius bankruptcy.
Anemoy Capital SPC Limited is approved and licensed as a BVI Professional Fund by the FSC and is registered as a Money Services Business with the US Treasury FinCEN. The Portfolio Supplements for the currently two segregated portfolios including The Janus Henderson Anemoy Treasury Fund are approved by the FSC on a portfolio-specific basis.
Janus Henderson Investors UK is an investment manager regulated by the the Financial Conduct Authority (Registration Number 906355)
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Would Arbitrum’s assets be bankruptcy remote from your own entity and its officers/key contributors? If so, please explain the legal and contractual basis. On a confidential, non-reliance basis, provide any third party legal opinions to support the conclusions.
BVI professional funds and segregated portfolio companies provide the best possible investor protection and bankruptcy remoteness because the segregation of the assets and the rules of distribution of such assets upon liquidation are embedded in statutory law. Potential investors can refer to Section 155 of the BVI Business Companies Act (revised 2020) for the clear rules on asset distribution.
A legal opinion confirming that Fund investors have full and exclusive recourse under law to the Treasuries and cash assets of the Fund from our counsel Ogier has been sent privately.
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How are Arbitrum’s assets protected vis-a-vis the bankruptcy of the brokerage or applicable financial institution (e.g., bank deposit insurance, securities insurance, etc.)?
While a bankruptcy of an Anemoy service provider would not directly impact Arbitrum or its assets, the bank and custodian used by Anemoy are both covered under US government insurance schemes through the Federal Deposit Insurance Corporation (FDIC) and the Securities Investor Protection Corporation (SIPC) respectively.
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Does the Issuer issue more than one asset? If so, what is the priority relationship between different asset classes?
Anemoy has also tokenized the Anemoy DeFi Yield Fund. A fund offering investors access to DeFi yields. Furthermore, Anemy will launch a couple more funds in the coming months in other fixed income and equity asset classes. This will complement each other, allowing investors to achieve a blended strategy with high DeFi yields and stable treasury rates.
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Provide a detailed cash flow diagram that shows the flow of funds from ARB/Fiat conversion, investment in underlying asset, payment of expenses, sale of underlying asset, and repayment (Fiat/ARB conversion), including the counterparties and legal jurisdictions involved.
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Issuer: Anemoy Capital SPC Limited, a BVI segregated portfolio company and BVI professional fund, approved and licensed by the FSC
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Sub-Advisor and Sub-Investment Manager : Janus Henderson Investors (JHI)
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Fund Administrator: Trident Trust (Cayman)
→ Investor onboarding (KYC, AML, wallet validation)
→ NAV calculation/verification
→ Investor updates/statements
→ Asset updates/valuation
→ Sanctions violations
→ Accounting
→ Audit support
→ Other administrative tasks -
Fund Auditor: MHA Cayman, for annual audit and reporting to the FSC
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Investment Manager: Anemoy Asset Management Limited
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Prime Broker: StoneX
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Custodian: Pershing
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US Broker Account: StoneX prime broker account
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US Banking Services: Silicon Valley Bank, a division of First-Citizens Bank for wire transfers and other payment services
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Exchange Agent: Circle Internet Financial, LLC
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Oracle: Chronicle
→ Providing independent asset pricing and NAV information from the Fund Administrator
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Describe anticipated tax consequences (if any) in transacting on the underlying and/or receipt of yield.
The Fund is located on the BVI, a tax-free offshore location, and open to non-US professional investors, excluding sanctioned persons, organizations, and jurisdictions. There are no tax impacts on the BVI. Investors will be registered with their tax number and tax jurisdiction and need to report taxes in their home country. Investors from other tax-free jurisdictions like the Cayman Islands will have no tax impacts or tax reporting duties. Please consult your tax advisor for details. This is not tax advice.
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Describe the process and expected timeline for liquidation of assets, if given instructions to do so by Arbitrum governance.
Standard Redemption Flow:
- Investors lock their assets into the JTRSY redemption contract, accessible 24/7/365.
- The fund manager (e.g., Janus) directs StoneX to liquidate the necessary assets to fulfill redemption requests.
- Proceeds in USD are transferred from the brokerage account to a U.S. bank account.
- The funds are then moved from the bank account to the on-chain reserve managed through the Centrifuge app under Anemoy’s control.
- The fund administrator calculates the official NAV (Net Asset Value), determining the payout amount for the investor.
- Once the redemption is finalized, the payout becomes claimable by the investor.
In the interest of reducing cost and enhancing liquidity and processing cycles, Janus Henderson Investors is in the process of a front-to-back analysis of the above operational structure and processes and plans to make suggestions for enhancements and improvements. The entire standard process takes 8-48 hours depending on the time of redemption request.
Instant and Intraday Redemption Flow
Anemoy is proud to share a recent announcement around the Anemoy Liquidity Network. Anemoy has strategically secured partnerships for liquidity vehicles and risk management, with a focus on addressing both the immediate needs and future state of DeFi. Anemoy has implemented a tiered liquidity solution with trusted strategic partners. This solution is called the Anemoy Liquidity Network (ALN) and includes:
| Liquidity Solution | Details | Capacity | Cost | Availability |
|---|---|---|---|---|
| Instant Redemption Facility 1 | Up to $100,000,000 facility | 100,000,000 - USDC | 10 basis points per redemption | 24/7/365 |
| Same-Day Redemption Facility | Intra Day /Repo facility to support block size redemptions. | Fund AUM dependent | 15 basis points per redemption | Same-day settlement, Banking Hours |
For both instant redemption facilities, an instant redemption contract will be deployed that enables JTRSY holders to lock JTRSY fund shares, which can then be swapped for USDC by the liquidity partners, at predetermined fees. The swaps will be executed at the latest fund share price provided by the Chronicle RWA oracle.
Anemoy’s Liquidity Strategy
Anemoy is emulating the successful framework of ETF Capital Markets by integrating a network of liquidity providers that are committed to pre-agreed contractual terms, particularly during times of market volatility. To ensure that liquidity is available when needed, Anemoy has secured multiple contractual agreements with these providers. This strategy mitigates the risk of single points of execution failure or slippage during periods of heightened volatility.
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What amount of first-loss equity will Sponsor provide to ensure over-collateralization, how is the first-loss equity denominated, and what is the source of capital?
N/A. There is no need for first-loss equity.
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Describe the liquidity and stability of the proposed underlying assets, including anticipated settlement times from the sale of the underlying to the repayment of ARB.
The market value of U.S Treasury bills is around $27 trillion according to the St. Louis Fed, making it the most liquid asset class in the world. We expect from the sale of treasuries to repayment of ARB to be around 8-48 hours.
The underlying government T-bills can be sold T+0 on business days.
Further, please see question #9 above around the Anemoy Liquidity Network which enables instant and intraday redemptions for JTRSY.
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If relying on the blockchain for any of the transactional flows, please describe any blockchain derived risks and mitigations.
The investment and redemption process, as well as the tokenization and origination process, is fully automated by smart contracts. This creates a transparent and auditable trail.
The flow of funds onchain is fully restricted through a combination of account abstraction and custom permissioning built into the Centrifuge protocol. Once stablecoins are moved into the pool contract, the asset manager can trigger a transfer only to the predetermined off-ramp, specifically the Circle wallet. Vice versa for repayments and redemptions, any on-ramped funds are directly moved to a wallet that can only be used to move stablecoins into the pool.
The contracts themself have been extensively audited, to reduce the risk of technical issues, by Spearbit, SR Labs, a Code4rena audit, and more. More recently an extensive invariant test suite has also been developed, in partnership with Recon.
N/A. The investment restrictions set forth in the Portfolio Supplement expressly prohibit the use of leverage, hedging and derivatives.
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List all the third party counterparties linked to your assets including and not restricted to prime broker if any, custodian, reporting agent, banks for derivatives or loans and provide primary contact details for the third party counterparties
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Issuer: Anemoy Capital SPC Limited, a BVI segregated portfolio company and BVI professional fund, approved and licensed by the FSC
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Sub-Advisor and Sub-Investment Manager : Janus Henderson Investors (JHI)
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Fund Administrator: Trident Trust (Cayman)
→ Investor onboarding (KYC, AML, wallet validation)
→ NAV calculation/verification
→ Investor updates/statements
→ Asset updates/valuation
→ Sanctions violations
→ Accounting
→ Audit support
→ Other administrative tasks -
Fund Auditor: MHA Cayman, for annual audit and reporting to the FSC
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Investment Manager: Anemoy Asset Management Limited
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Prime Broker: StoneX
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Custodian: Pershing
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US Broker Account: StoneX prime broker account
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US Banking Services: Silicon Valley Bank, a division of First-Citizens Bank for wire transfers and other payment services
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Exchange Agent: Circle Internet Financial, LLC
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Oracle: Chronicle
→ Providing independent asset pricing and NAV information from the Fund Administrator
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Can you explain how is risk management (investment and operational) being done? Can you provide a copy of your risk management policy?
Anemoy sets a benchmark in financial security. The T-Bill investment carries essentially no investment risk and duration risk. Operational risk is minimized due to a highly simplified and streamlined process. Legal and regulatory risk is minimal as the fund is fully licensed under BVI law. The BVI Financial Services Commission is one of the world’s only regulators actively allowing and regulating funds such as the one being proposed. This allows Anemoy to not provide services in the gray areas of the law.
Trident Trust oversees meticulous KYC/KYB/AML protocols. Anemoy ensures stringent BVI compliance standards are met, safeguarding against illicit activities. Daily NAV checks are completed and overseen by seasoned Professional Fund Administrators and reviewed by Trident Trust to maintain stability and integrity for the pool. Access to pivotal financial hubs like Circle, StoneX (Custodian), and bank accounts are prudently restricted, bolstering asset protection measures.
Performance reporting
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What are your proposed performance benchmarks? If this is substantially different from the underlying assets, please explain why.
Our performance benchmark is the same as the underlying assets that make up the fund, a mix of U.S Treasury Bill rates with maturities of 0-3 months. Anemoy and Janus Henderson does not anticipate the fund performance to be any different than the underlying assets that it consists of before potential fees.
Below is the current yield curve as of 3/17/25 pertaining to U.S. Treasury bills.
| 1M | 2M | 3M |
|---|---|---|
| 4.37% | 4.32% | 4.29% |
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Describe the content, format, preparation process, and cadence of performance reports. This should include proof of reserves, if appropriate. Please include a sample report.
The Janus Henderson Anemoy Treasury Fund provides a suite of advanced reporting features through the Centrifuge protocol, offering investors unprecedented access to fully transparent, real-time, onchain data. All transactions, both onchain and offchain, are seamlessly captured and recorded in one unified platform.
- Unprecedented reporting including Balance Sheet, Profit & Loss and Cash Flow statements for assessing full portfolio performance.
- Effortlessly track the historical growth of the Net Asset Value (NAV) and the token price providing a clear and transparent way to assess pool performance.
- Comprehensive information on key metrics, holdings, and transaction history, offering a thorough insight into the individual asset’s performance.
Additionally the fund, as a licensed and regulated BVI professional fund, has an FSC-approved Fund Administrator and Fund Auditor.
Trident Trust, the Fund Administrator, verifies any change of AUM (buying or selling or rollover of maturing T-bills) and updates the NAV daily, or before any investment or redemption is executed. Trident Trust provides monthly updates and adjustments to the NAV using the Centrifuge protocol.
MHA Caymans, the Fund Auditor, performs annual fund audits, reviews fund and investor accounting, AUM/NAV changes, and regulatory compliance. The audit is currently performed and will be submitted to the FSC.
The next section also describes the underlying accounting processes and further reporting details as well as highlights planned improvements from our partnerships with Chronicle as decentralized oracle and JHI as sub-advisor.
Anemoy works with its Fund Administrator Trident Trust, who assists Anemoy with bookkeeping, daily NAV updates, and day-to-day accounting, as well as tasks such as bank account reconciliations and reviews of external accounting records. Trident Trust prepares annual accounts and consolidated financial statements under IFRS and supervises and coordinates the annual audit process with our Fund Auditor MHA Caymans.
Furthermore, Trident Trust tax compliance services can support our clients in the estimation or review of tax provisions, the preparation or review of corporate and withholding tax returns, and can assist with tax authority enquiries, or the analysis and assistance concerning tax assessments and tax payment management.
As mentioned above in the previous section Anemoy is using the Centrifuge protocol. You have full onchain transparency and immutability on all fund details, including asset performance and bank account holdings. The journal of single transactions as well as monthly balance sheets and many more details are publicly available. Please check the reporting tab on the Centrifuge app here.
The planned Chronicle oracle price feeds will replace Anemoy’s update and will be another step towards trust minimization and removing the requirement of trust in intermediaries and centralized service providers.
Also, the sub-advisory of JHI will enable us to further improve our accounting and reporting capabilities. They plan to act as the full portfolio manager and would interact in this capacity directly with Trident Trust. This will include the public listing of the Fund on their website here and will also show daily NAV and asset performance information in addition to the Centrifuge app.
In addition to fund administration as a continued effort, a fund auditor does an annual audit and FSC reporting. Our fund auditor MHA Cayman performed its first fund audit for December 31, 2024.
Pricing
Please see the Subscription Agreement and Private Placement Memorandum (PPM) + Portfolio Supplement shared privately.
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Fee summary: Inclusive of the full scope of services requested. Product Fee schedule If asset based Fee calculation for our plan if asset based Annual fee if flat fee Any other fees (including redemption or minting fees)
There is a 25bps annual management fee for JTRSY.
Fees are withheld from the NAV of the fund, hence withheld from the token price. Fees are withheld on a daily basis.
Standard redemptions are free, for instant redemptions, please see the section about the Anemoy Liquidity Network (ALN).
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Describe frequency of fee payment and its position vis-a-vis payment priority compared with other expenses (i.e., cash waterfall)
The fund administrator calculates fees. Fee calculations are part of the fund administration and reporting. The fees are charged on a daily basis onchain in USDC with a direct impact on the NAV and JTRSY token price. That means all fees are paid before any redemptions are satisfied.
Smart Contract/Architecture
The Centrifuge protocol has received many audits over the years. The most recent audits were performed by Spearbit (via Cantina), SRLabs, and a Code4rena audit contest. The list of all Centrifuge audits including reports can be found here in our GitHub.
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Is the project permissioned? If so how are you managing user identities? Any blacklisting/whitelisting features?
Yes, Anemoy is KYC only and open to non-U.S professionals. User identities are stored in a database with our fund administrator.
Centrifuge is building towards adoption of institutional DeFi, and will always prioritize full compliance with Issuers on the protocol.
Centrifuge is currently available on Arbitrum, Base, Celo, Ethereum and our RWA L1, Centrifuge Chain. With plans to expand to Plume and more. There are cross-chain interactions between the EVM networks and Centrifuge Chain, to maintain bookkeeping.
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Are the RWA tokens being used in any other protocols? Please describe the various components of the ecosystem
JTRSY tokens are currently integrated with Morpho and soon, Aave, to allow for collateral use cases within DeFi.
Link to JTRSY/verUSDC Morpho market.
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How are trusted roles/admins managed in the system? Which aspects of the solution require trust from users?
The Janus Henderson Anemoy Treasury Fund is a regulated BVI professional fund. The British Virgin Islands Financial Services Commission (FSC) requires fund administration by a licensed fund admin and annual audits by a licensed fund auditor. The fund admin has access to all third-party service provider accounts and does investor onboarding and reporting. Additionally, the Centrifuge protocol gives real-time onchain visibility of all assets, the NAV (including fees and cash reserve), and the JTRSY token price.
The Centrifuge smart contracts enforce rules around administration of the pool, ownership of assets from issuance to purchase by an investor, and permissions around who may access a pool.
The tokens are ERC-20 standard compliant, with permissioning built in.
Supplementary
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Please attach any further information or documents you feel would help the screening committee or ARB tokenholders make an informed decision.
N/A