STEP 2 Application - Spiko (USTBL)

DAO Programs & Initiatives STEP Applications & Updates
1

Applicant information

Name: Spiko

Address (Headquarters): 16, rue des Immeubles Industriels

City, State, Postal Code: Paris, France, 75011

Country: France

Website: https://www.spiko.io/

Primary contact name, title and methods of contact:

Key product information:

  • Expected Yield: ~4%
  • Expected Maturity: Portfolio’s maximum weighted average maturity (WAM) set at 60 days
  • Underlying asset: Treasury Bills issued by the U.S. Department of the Treasury, Overnight Reverse Repos collateralized by U.S. Treasuries, Deposits at JPMorgan Chase NY Branch.
  • Transaction size:
    • Minimum: 1 USD (1,000 USD for first subscription)
    • Maximum: n.a.
  • Current AUM for product: $71M
  • Current AUM for issuer: $200M
  • Volume of transactions LTM: $401M
  • Source of first-loss capital: not applicable

Basics and background

  1. How will this investment improve Arbitrum’s RWA ecosystem?

    Spiko is proud to be the second-largest issuer of tokenized T-Bills on Arbitrum, having launched just two months ago on the network. Our platform has grown significantly and purely organically, with no prior allocation from the DAO to date (having launched after the STEP1 allocation), and now counts over a thousand active addresses. This investment will further enhance Arbitrum’s RWA ecosystem by providing the DAO with improved diversification through a fully regulated, onshore EU setup that is unique in the industry. Our stringent regulatory framework and robust operational infrastructure ensure that investors benefit from superior legal clarity and enhanced asset protection, while accessing high quality treasury products—all of which contribute to a more resilient and diversified treasury reserve strategy for the Arbitrum ecosystem. Beyond the DAO’s treasury, Spiko is committed to maximizing collaboration with the Arbitrum ecosystem by enhancing the composability and expanding the use cases of its RWAs within the ecosystem.

  2. Identify key management personnel and individual experience. Also include third parties utilized for managing assets and their qualifications.

    • Key Management Personnel:
      • Paul-Adrien Hyppolite – Co-founder & CEO: Former deputy head of the French Treasury’s financial markets division. Paul-Adrien has several years of experience in finance and financial regulation, having worked at Lazard, Antin, and the European Commission. He graduated in Economics and Finance from the Ecole Normale Supérieure and the Corps des Mines.
      • Antoine Michon – Co-founder & COO: Former ministerial advisor to the French Government on the digital transformation of public services. Antoine also worked at Palantir Technologies as a deployment strategist. He graduated in Applied Mathematics from the Ecole Polytechnique and the Corps des Mines.
      • Samuel Briole – CTO: Former senior software engineer in several start-ups including P00ls and Inato. He graduated in Physics from Ecole Polytechnique and in Quantum Physics from the Ecole Normale Supérieure.
      • Victor Charpiat - Head of Legal and Compliance: Former lawyer specialized in financial and crypto-assets regulation. He joined the Paris office of Kramer Levin Natfalis & Frankel LLP in 2018 where he advised many French and global crypto companies in their DASP application with the French regulators. He holds law degrees from SciencesPo Paris and Université Paris II-Panthéon Assas.
    • Third Parties Utilized:
      • Asset Manager: Twenty First Capital – A regulated portfolio management company approved by the French Financial Markets Authority with several billion USD under management across various asset classes including money markets, fixed income, commodities, and real estate.
      • Fund Administration & Custody: CACEIS Fund Administration and CACEIS Bank – Responsible for daily NAV calculation, safeguarding assets, and ensuring compliance with regulatory requirements. CACEIS is one of the world’s largest fund administrators and depositary banks. A subsidiary of the globally systemic Credit Agricole group, CACEIS holds €5.3 trillion in assets under custody and €3.4 trillion in assets under administration.
      • Fund Auditor: PwC serves as the statutory auditor of the MMF. In compliance with current regulatory requirements, it conducts two audits per year.
    • Additional Service Providers:
      • JPMorgan Chase: Serves as CACEIS Bank’s correspondent bank for the U.S. dollars.
      • BNY Mellon: Appointed as CACEIS Bank’s sub-custodian for U.S. Treasury Bills.

  3. Describe any previous work by the entity or its officers/key contributors similar to that requested. References are encouraged.

    Due to its relatively recent existence (products launched in mid-2024), Spiko has not yet had the opportunity to apply to many Web3 industry RFPs. In particular, Spiko was not yet live at the time of the previous STEP application (STEP1). That being said, Spiko currently serves over 1,000 active investors, including over 500 legal entities. It is, by far, the largest user base in the tokenized money market industry. We have already partenered with several Web3 foundations to improve their cash management. References can be provided upon request from the evaluation committee.

  4. 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, neither Spiko nor Spiko SICAV, nor any of its officers/key contributors have been subject to any enforcement action, criminal action, or default on legal or financial obligations.

  5. Describe any conflicts of interest for your entity and key personnel.

    We have identified no potential conflict of interest in the context of this application.

  6. Insurance coverages, guarantees, and backstops Name of insurer or guarantor Per incident coverage Aggregate coverage

    SPIKO is covered by three insurance policies:

    1. Civil liability insurance for investment services provided to customers, including investment advice and the reception and transmission of orders on financial instruments.
      1. This insurance is a regulatory requirement.
      2. It is provided by MMA.
      3. Coverage of up to 2,500,000 EUR.
    2. Cyber insurance for the SPIKO platform, which is used by both fund investors and the asset manager.
      1. This insurance is not a regulatory requirement.
      2. It is provided by AXA.
      3. Coverage of up to 300,000 EUR.

  7. Historical tracking error in your proposed product, or similar to that being proposed Product 2024 2023 2022 2021

    Compounded EFFR since launch (24-06-01) = 3.91%

    Compounded USTBL return since launch (24-06-01) = 3.62%

    Tracking error = 29 bps

  8. Brief reason for above tracking error

    The tracking error can be attributed to the fees charged by the Fund. Until February 25th, 2025, the fees were set at 40 bps, after which they were reduced to 25 bps. Consequently, we expect a gradual reduction in tracking error relative to the benchmark (compounded EFFR).

  9. Please describe any experience your firm has in working with decentralized organizational structures

    Investors in the Spiko Money Market Funds (MMFs) include many Web3 organizations that use USTBL (token name of the Spiko US T-Bills MMF) and/or EUTBL (token name of the Spiko EU T-Bills MMF) to earn daily returns at the USD or EUR risk-free rate on their treasury holdings. Spiko has successfully onboarded Web3 foundations and DAOs. We are happy to provide further details and references from our partners and clients upon requests. Last but not least, Spiko maintains strong relationships with several decentralized organizations within the DeFi space, and is committed to expanding its presence in this sector.

  10. What is your entity’s current assets under management, assets held in trust, total value locked, or equivalent metric for your legal structuring?

    As of March 19, 2025, Spiko US T-Bills Money Market Fund’s AuM is $70.8M, of which:

    • $40.6M (39,127,087 outstanding shares) on Ethereum
    • $13.5M (13,011,008 outstanding shares) on Polygon
    • $11.6M (11,136,819 outstanding shares) on Starknet
    • $5.1M (4,946,910 outstanding shares) on Arbitrum One

  11. How many of these assets held are present on Arbitrum One, if any?

    As stated above, $5.1M, which represents ~7.2% of the Fund’s shares, are on Arbitrum One.

    In addition, as of March 19, 2025, over €19.5M worth of Spiko EU T-Bills Money Market Fund shares have been natively minted on Arbitrum One.

Plan design

  1. 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 Spiko US T-Bills Money Market Fund is a sub-fund of the Spiko SICAV.

    A SICAV (which stands for “Société d’Investissement à Capital Variable”) is a widely used European investment fund structure, allowing investors to subscribe to and redeem shares while the fund’s assets are professionally managed.

    Incorporated in France under French law, the Spiko SICAV currently manages two sub-funds approved by the French Financial Markets Authority (Autorité des Marchés Financiers) as short-term variable net asset value MMFs under the UCITS Directive (Directive 2009/65/EC) and the MMF Regulation (Regulation (EU) 2017/1131).

    UCITS (which stands for “Undertakings for Collective Investment in Transferable Securities”) funds are the European Union’s equivalent to U.S. mutual funds. Before a UCITS can be marketed to investors, its prospectus must be approved by a national competent authority of the European Union. This process is similar to that of a mutual fund’s approval by the SEC in the United States.

    The Fund’s prospectus references the smart contracts that officially serve as the shareholder register.

    Public Address of Share Register
    Public Address of Share Register986×406 20.4 KB

    Under our regulatory and legal framework, blockchains serve as the definitive source of truth for the shareholder register, rather than merely being an on-chain replica of a separate centralized database. Investors have the flexibility to custody the Fund’s shares (USTBL) at their discretion using any wallet technology compatible with the Ethereum Virtual Machine (or Cairo VM for Starknet).

    The following table summarizes the key characteristics of the Spiko US T-Bills Money Market Fund.

    Spiko US T-Bills MMF (USTBL)
    ISIN FR001400ODM9
    Bloomberg ticker SPKUSMM
    Currency $ USD
    Type of fund UCITS short-term VNAV Money Market Fund under EU law
    Fund domicile France
    National competent authority French Financial Markets Authority (AMF)
    Legal structure SICAV
    Investment policy T-Bills issued by the U.S. Treasury and ORR collateralized by U.S. Treasuries
    Benchmark Effective Federal Funds Rate (EFFR)
    Maximum weighted average maturity 60 days
    Use of income Accumulating
    Fees Management fees: 0.15% per annum; Admin. fees: current charge of 0.10% per annum (will be reduced to 8 bps at $100M AuM and 5 bps at $500M AuM); Subscription / redemption fees: 0.00% (none)
    Available networks Ethereum, Polygon PoS, Arbitrum One, Starknet, Etherlink, Base
    Minimum subscription amount 1,000 USD (then 1 USD)
    Minimum redemption amount 1 USD
    Max. subscription and redemption amount None

    Underlying assets:

    • The Fund’s portfolio is invested in:

      • T-Bills issued by the U.S. Department of the Treasury, with a maturity of less than 6 months,
      • (Reverse) repos collateralized by U.S. Treasuries.

    • The Fund maintains a USD balance at its correspondent bank for liquidity management purposes, with the amount not exceeding 10% of its portfolio, as outlined in the prospectus (N.B.: the USD correspondent bank appointed by the Fund’s depositary bank is JPMorgan Chase - New York).

    • The portfolio’s total maximum weighted average maturity is 60 days. N.B.: this 60 days limit is a regulatory requirement resulting from the Fund’s approval as a short-term variable net asset value MMF under EU law. As a result, the Fund’s depositary bank has a regulatory responsibility to ensure that the duration cap is adhered to, providing investors with a high level of assurance that it will be upheld.

    • As of March 19, 2025, the underlying assets weighted average maturity is ~43 days and the Fund’s holdings are the following:

      % of Portfolio Asset Name - ISIN Amount (USD) Maturity (days)
      10.89 United States Treasury bill expiring on 3 April 2025 - US912797MV69 7,686,338 16
      9.56 United States Treasury bill expiring on 20 May 2025 - US912797PJ05 6,750,491 63
      9.04 United States Treasury bill expiring on 8 April 2025 - US912797NY99 6,384,905 21
      8.75 United States Treasury bill expiring on 15 April 2025 - US912797NZ64 6,180,141 28
      8.13 United States Treasury bill expiring on 12 June 2025 - US912797LN52 5,742,248 86
      7.78 United States Treasury bill expiring on 1 April 2025 - US912797NT05 5,491,538 14
      7.36 United States Treasury bill expiring on 25 March 2025 - US912797NS22 5,196,307 7
      6.98 United States Treasury bill expiring on 15 July 2025 - US912797QA86 4,930,681 119
      6.84 Current account held at CACEIS Bank, a subsidiary of Crédit Agricole 4,829,106 0
      6.19 United States Treasury bill expiring on 6 May 2025 - US912797PC51 4,375,080 49
      6.06 United States Treasury bill expiring on 24 April 2025 - US912797NC79 4,281,670 37
      5.91 United States Treasury bill expiring on 13 May 2025 - US912797PH49 4,172,759 56
      2.38 United States Treasury bill expiring on 27 May 2025 - US912797PK77 1,686,415 70
      2.09 United States Treasury bill expiring on 1 July 2025 - US912797PU59 1,481,737 105
      1.96 United States Treasury bill expiring on 3 June 2025 - US912797PL50 1,387,566 77

    • The exhaustive list of assets held in the portfolio is updated daily and can be viewed here: Spiko Dollar Money Market Fund.

    Fund credit quality:

    • On January 2025, Particula - a leading platform of rating and analytics in the token economy - assigned an AA rating (i.e., Investment grade) to the issuance of the USTBL token by Spiko SICAV.
    • More details on the rating process and conclusion here: Particula Rating Abstract: SPIKO ($USTBL), January 2025

  2. Do investors have any shareholder, investor, creditor or similar rights?

    USTBL are shares of the Spiko US T‑Bills Money Market Fund, which means they grant shareholder rights to the investors.

    As stated in Particula’s rating report: “The USTBL token offers investors direct ownership in the Spiko US T-Bills Money Market Fund, providing a clear legal entitlement to the underlying assets. Each token represents a share in the fund, granting holders specific shareholder rights, including participation in governance through voting rights at the general assembly. This allows investors to vote on critical matters such as the election of the board of directors and the approval of the fund’s annual accounts, ensuring direct involvement in the fund’s strategic and operational oversight. The fund’s structure ensures equitable treatment of all shareholders, maintaining transparency and a non-discriminatory approach to both investment and redemption processes. Daily redemption rights, based on the fund’s Net Asset Value (NAV) as outlined in the prospectus, provide investors with flexibility and control over their investments, further reinforcing the alignment of shareholder interests with fund operations. This structure reduces ambiguity regarding asset ownership and mitigates intermediary risks by ensuring a direct link between investors and the underlying assets. The integration of governance participation, liquidity, and robust regulatory oversight enhances operational clarity and investor confidence. While the framework is robust, ongoing reliance on the fund’s management and technical systems necessitates continued diligence to maintain its high operational and governance standards.”

    Ownership of USTBL grants voting rights at Spiko SICAV’s general shareholders’ meeting. USTBL holders, for instance, vote to elect the board of directors, who are responsible for safeguarding the interest of shareholders.

  3. 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.

    As mentioned earlier, the Spiko US T‑Bills Money Market Fund is a sub‑fund of the Spiko SICAV incorporated in France under French law. The Fund is approved as a UCITS short‑term variable net asset value Money Market Fund under the UCITS Directive (Directive 2009/65/EC) and the MMF Regulation (Regulation EU 2017/1131).

    The Fund’s legal and contractual structure is designed to comply with the strict investor protection measures imposed by these regulations. Regulatory oversight is conduced by the French Financial Markets Authority (Autorité des Marchés Financiers). Key counterparties include CACEIS Bank as the depositary and custodian (with BNY Mellon as sub‑custodian), JPMorgan Chase as the correspondent bank, and Twenty First Capital as the asset manager, all operating under their respective regulatory frameworks in France or the United States.

    Supplementary documents: Prospectus of the Spiko SICAV; USTBL details on the AMF’s list of regulated investment funds

  4. 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.

    Yes. As a regulated investment adviser under French law, Spiko is prohibited from holding investors’ funds on its own balance sheet. Within the Spiko SICAV structure, the Fund’s assets are ring‑fenced and are never commingled with the assets of either Spiko or its asset manager Twenty First Capital. The depositary bank (CACEIS Bank) is legally responsible for safeguarding the Fund’s assets in compliance with UCITS regulations. This framework ensures that, even in the event of Spiko or the asset manager’s bankruptcy, the Fund’s assets remain segregated and protected.

  5. 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.)?

    There are 2 bankruptcy cases to distinguish:

    1. Bankruptcy of the Asset Manager (Twenty First Capital - TFC)

      In accordance the UCITS regulations, the Fund’s assets are ring-fenced and are never commingled with the assets of Twenty First Capital. Therefore, they would not be affected in the event of a bankruptcy of the Asset Manager.

    2. Bankruptcy of the Custodian Bank (CACEIS)

      The Fund’s assets are held by CACEIS Bank, a depositary bank subject to stringent regulatory oversight under the UCITS Directive. The depositary is legally required to ring‑fence the Fund’s assets, ensuring that in the event of its insolvency or that of its sub‑custodian, the assets are protected from being used to satisfy creditors’ claims. Additionally, CACEIS Bank’s robust regulatory framework and its use of a sub‑custodian, BNY Mellon, further safeguard the assets by segregating them from the bank’s own balance sheet, thereby providing an added layer of protection for investors’ funds

  6. Does the Issuer issue more than one asset? If so, what is the priority relationship between different asset classes?

    The Spiko SICAV currently manages 2 sub‑funds:

    • The Spiko US T‑Bills Money Market Fund (USTBL) and,
    • The Spiko EUR T-Bills Money Market Fund (EUTBL).

    Both sub-funds hold equal priority, with no asset class subordinated to the other. The assets and liabilities of the two sub-funds are fully segregated. This sub-fund structure is commonly used for the European equivalent of U.S. mutual funds.

  7. 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.

    Subscriptions and redemptions in the Fund can be made either in fiat through traditional settlement/messaging systems (particularly SWIFT for USD) or in stablecoins via various blockchain networks, including Arbitrum One. Since the Fund requires USD to purchase T-Bills and minimize cash drag, it never holds USDC on its balance sheet.

    Redemption ARB Flow
    Redemption ARB Flow4416×960 109 KB

  8. Describe anticipated tax consequences (if any) in transacting on the underlying and/or receipt of yield.

    The Spiko SICAV is inherently fiscally transparent, meaning that the income it generates and any capital gains it realizes are not taxes at the Fund level.

    As a capitalization fund, the Fund reinvests any income it generates back into itself, meaning it does not distribute yields to investors. Investors can only redeem shares on the primary market or sell them on the secondary market. In either case, they would realize a capital gain, which would be taxed according to the laws of their jurisdiction.

    Non-resident investors will not be subject to a French withholding tax in relation to any income derived from their ownership of the Fund (i.e. in that case, a capital gain). They also don’t need to perform any fiscal declaration in France. Consequently, these capital gains should be taxed exclusively in the juridiction of the Arbitrum entity which will invest in the Fund. We can share upon request a legal memo from an international firm confirming this tax analysis.

  9. Describe the process and expected timeline for liquidation of assets, if given instructions to do so by Arbitrum governance.

    Upon receiving instructions from the Arbitrum DAO to redeem its shares, the Fund will process redemption orders in full compliance with the conditions specified in the prospectus.

    Redemption Process and Timeline:

    • Redemption orders received by 10:30 AM CET on any business day are processed the same day by the Asset Manager, and executed using the NAV calculated and published on that day.
    • Redemption orders received after 10:30 AM CET on a business day, or at any time on a non-business day, are processed on the next business day and executed using the NAV calculated and published on that day.

  10. 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?

    Generally, regulated money market funds like ours do not involve over-collateralization or first-loss equity. The Fund is prohibited from incuring debt and holds highly secure assets, namely U.S. T-Bills, Overnight Reverse Repos collateralized by U.S. Treasuries, and deposits at JPMorgan Chase NY.

  11. 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 Fund’s portfolio is primarily invested in U.S. T-Bills, the safest and most liquid financial assets available. To mitigate interest rate risk, the Fund maintains a maximum weighted average maturity of 60 days, with the current weighted average maturity standing at approximately 26 days. Additionally, the Fund facilitates subscription and redemption requests on every business day. The right to redemption on each business day is contractually defined in the prospectus.

  12. If relying on the blockchain for any of the transactional flows, please describe any blockchain derived risks and mitigations.

    Shares of the Spiko US T‑Bills Money Market Fund are issued as ERC‑20 tokens, utilizing OpenZeppelin’s audited smart contract implementations. The investor allowlist is managed by the PermissionManager contract, and redemptions are processed through the Redemption contract. The token’s NAV is published daily on‑chain via an Oracle contract. All smart contracts have been audited by Trail of Bits (October 2023) to mitigate risks including smart contract vulnerabilities and on‑chain data risks.

  13. Does the product rely on any derivative product (swaps, OTC agreements)?

    None, as specified in the Fund’s prospectus.

  14. 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

    • Custodian/Depositary Bank: CACEIS Bank (France) – with BNY Mellon acting as sub‑custodian for U.S. Treasury Bills.
    • Correspondent Bank: JPMorgan Chase (USA) for USD holdings and transfers.
    • Asset Manager: Twenty First Capital (France), approved by the French Financial Markets Authority.
    • Fund Administration: CACEIS Fund Administration (France), responsible for daily NAV computation.
    • Auditor: PwC (France), conducting independent financial audits.
    • On‑ramp/Off‑ramp Services: Provided through a Circle Mint account.
    • Primary contact for Spiko is: Paul‑Adrien Hyppolite, Co‑founder & CEO

  15. Can you explain how is risk management (inv and operational) being done? Can you provide a copy of your risk management policy?

    Investment risk is managed by Twenty First Capital in accordance with the stringent guidelines imposed under the UCITS Directive, while operational risk is addressed by Spiko Finance through robust KYC/AML processes and the use of a permissioned token model. Daily NAV computation by CACEIS Fund Administration—coupled with independent checks by the asset manager—ensures ongoing oversight of market and valuation risks.

Performance reporting

  1. What are your proposed performance benchmarks? If this is substantially different from the underlying assets, please explain why.

    The Fund’s management objective is to achieve a net performance, after fees, that aligns with the federal funds rate (EFFR). This benchmark is selected as it closely reflects the short‑term interest rate environment, which directly impacts the performance of U.S. Treasury Bills, the Fund’s underlying assets.

  2. 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 Fund Administrator, CACEIS Fund Administration, computes the daily NAV of the Fund using a mark‑to‑market valuation approach in compliance with UCITS and MMF regulations. The process is as follows:

    • NAV is calculated on each business day of the Paris Stock Exchange.
    • The computed NAV is independently double‑checked by the Asset Manager.
    • Once confirmed, the NAV is reported to the regulatory authorities (Autorité des Marchés Financiers) and broadcast to major traditional financial data providers such as Bloomberg and Morningstar, as well as updated on crypto data feed providers like CoinGecko.

    Daily performance reports include detailed portfolio composition (i.e., proof of reserves), latest NAV, and AuM figures—verified by the daily valuation process. You can access these daily updates directly on our website or through our public API.

  3. Who provides the performance reports in respect of the underlying assets?

    The performance reports for the underlying assets are provided by the Fund Administrator, CACEIS Fund Administration. The daily NAV computation is performed by CACEIS, with an independent verification by the Asset Manager, Twenty First Capital, ensuring accuracy before dissemination to regulatory authorities and data providers.

  4. Describe any formal audit process and timing of such audits.

    Biannual independent financial audits are conducted by PwC, a UCITS‑approved auditor recognized by regulatory authorities. These audits ensure compliance with regulatory standards and verify the financial accuracy of the Fund. In addition, annual accounts are approved by shareholders at the Spiko SICAV’s general assembly of shareholders.

Pricing

  1. Provide a copy of your standard contract, or one similar to what is being proposed here.

    Prospectus of the Spiko SICAV

  2. 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)

    Operations Fee schedule:

    • Subscription Fee: Free;
    • Redemption Fee: Free;
    • Asset management fees: 0.15% per annum;
    • Administrative fees: 0.10% per annum (will be lowered at 0.05% at $500m AuM).

    Apart from the fees described above, there are network gas fees:

    • Allowlist: Spiko pays the gas fees;
    • Investment: Spiko pays the gas fees;
    • Redemption: Investor pays the gas fees (token transfer);
    • Transfer on-chain: Investor pays the gas fees (token transfer).

  3. Describe frequency of fee payment and its position vis-a-vis payment priority compared with other expenses (i.e., cash waterfall)

    Fees are calculated and deducted daily on a prorata basis from the Fund’s assets prior to the calculation of the NAV. This daily fee deduction ensures that the asset management and administrative fees are continuously accounted for and prioritized in the cash waterfall structure, with no additional subscription or redemption fees applied beyond the network gas fees as noted.

Smart Contract/Architecture

  1. How many audits have you had and name of auditors? Please provide a copy of reports.

    Our Solidity smart contracts have been audited by Trail of Bits. The report is available here. Our Cairo smart contracts have been audited by Nethermind. The report is available here. Our web app has undergone two audits by Theodo Cloud. While their audit report is not publicly available, we can provide it upon request.

  2. Is the project permissioned? If so how are you managing user identities? Any blacklisting/whitelisting features?

    Before investing in the Fund, investors must complete Spiko’s KYC/AML process. As a regulated entity, Spiko complies with European anti‑money laundering (AML) and counter‑terrorist financing (CTF) regulations. Our ERC‑20s are permissioned and investors need to be allowlisted to own and transfer the token. The allowlist is persisted on a PermissionManager contract which is managed by Spiko. The connections between on-chain addresses and investors’ real‑world identities are stored off‑chain. Anonymous ownership of fund shares is not permitted in France, as in all major financial jurisdictions.

  3. Is the product present on several chains? Are there any cross chain interactions?

    USTBL is natively deployed on the following networks:

    • Ethereum;
    • Polygon PoS;
    • Arbitrum One;
    • Starknet;
    • Etherlink;
    • Base.

    While there are no cross-chain interactions currently, this feature is on our roadmap and will be available in the near future.

  4. Are the RWA tokens being used in any other protocols? Please describe the various components of the ecosystem

    USTBL and EUTBL are integral components of the treasury for several Web3 organizations, including foundations, service providers, and startups.

  5. How are trusted roles/admins managed in the system? Which aspects of the solution require trust from users?

    Trusted roles in the system are managed through our PermissionManager contract, which is managed by Spiko. The super-admin of this contract is a multisig (using Safe). Daily operations (allowlisting, mints, burns, etc.) are performed by a relayer we built in-house on top of Dfns’ wallet technology. This ensures that administrative actions are executed securely. Users must trust the integrity of these contracts and our capacity to perform the Fund’s daily operations correctly.

  6. Is there any custom logic required for your RWA token? If so please give any details.

    Upon subscribing to the Fund, shares are minted directly to the investor’s address on Arbitrum One. For redemptions, investors transfer their tokens to a Redemption contract (source code available here) using transferAndCall. Redemptions are processed daily, and once executed, the tokens are burned within the Redemption contract.

Supplementary

  1. Please attach any further information or documents you feel would help the screening committee or ARB tokenholders make an informed decision. If you prefer this not to be made public, it can be emailed to rwa@dao.arbitrum.foundation. Please mention in your application that documents have been emailed for committee review.

    The SPIKO US T-BILLS MONEY MARKET FUND is a public fund, meaning all related information, including the prospectus, fees, and more, must be publicly available. Additionally, it is required to treat all investors equally.

    No documents have been sent by email to the evaluation committee. However, we remain at the committee’s disposal to provide any additional information that may be necessary for the evaluation.