Anemoy Tokenized Apollo Diversified Credit Fund (ACRDX)

Research, firm shelf, model-client eligibility, and advisor selection are recorded separately. The scheduled date is the outside bound; new evidence can reopen the file sooner.

ACRDX is a share of a British Virgin Islands fund that owns shares of Apollo Diversified Credit Fund, a US interval fund lending to companies and against assets. Anemoy Capital SPC Limited, the Centrifuge-affiliated BVI professional fund that also issues JTRSY and JAAA, runs it as a separate segregated portfolio. The token is the share: Anemoy says the fund “issues its shares as the ACRDX token to investors,” and the register lives on Centrifuge. Holdings published on 20 July 2026 show 1,386,827 Apollo fund shares worth $30.7 million and $0.5 million in a Western Asset liquidity fund; the fact sheet gives 43 million USDC of assets at 29 June. The fund admits only non-US professional investors, with a minimum of 500,000 USDC. It takes money daily but can pay out only when Apollo makes one of its quarterly repurchase offers, so its liquidity is Apollo’s. It adds a 0.50% management fee to Apollo’s own costs; since its October 2025 launch it has returned 2.64% a year. The assessment is adverse on the comparison, not on the fund. It owns the same asset a client could own directly through a registered fund, with the same quarterly exit, and adds an offshore wrapper, a second fee, and on-chain powers to freeze and move balances. US persons may not hold it.

Research triggers: events that reopen the assessment or shelf decision
• Anemoy opens ACRDX to US investors under a published exemption, or publishes an offering memorandum that changes the investor class or the exit
• ACRDX gains a liquidity source independent of Apollo’s quarterly repurchase offers
• Apollo Diversified Credit Fund prorates or suspends a quarterly repurchase offer
• The FullRestrictions hook is replaced, the Root delay changes, or a freeze or authTransferFrom is used on a holder
• The Chronicle proof of asset shows Apollo fund shares below 90% of ACRDX NAV

The research file

What the fund holds

The fact sheet names the target as shares of Apollo Diversified Credit Fund (ticker CRDIX) and says those shares “are held directly by the Fund.” The July holdings table lists CUSIP 39822Y307 at $22.11 a share. Apollo’s fund is a registered closed-end interval fund that mixes corporate direct lending, asset-backed lending, and performing and dislocated credit, and it redeems only through quarterly repurchase offers. J.P. Morgan is custodian, Trident Trust (Cayman) administers the fund, and MHA Cayman audits it. Chronicle publishes a proof-of-asset feed for the pool, so the Apollo position can be checked against the tokens outstanding.

Who may hold, and how money gets out

The pool sheet and fact sheet say “Non-US Professional Investors” and a minimum of 500,000 USDC. Anemoy onboards each investor and adds the wallet as a member of the token’s transfer hook; the hook, Centrifuge’s FullRestrictions, refuses any transfer to a wallet that is not a member, which the reader confirmed by asking it on 2026-09-23. Subscriptions are daily in USDC, USDS, AUSD, or USDT. Redemptions are “subject to the timing of repurchases offered by the underlying Apollo Diversified Credit Fund.” If Apollo prorates a tender, ACRDX holders are prorated too, and there is no secondary market because the hook blocks it.

Who controls the token

On each EVM chain the ACRDX token answers to its wards: Centrifuge’s Root contract, which acts only after a 48-hour delay, and the Spoke and BalanceSheet contracts, which carry out the pool manager’s instructions sent from the Centrifuge hub. Through them the pool can mint, move a balance with authTransferFrom, freeze a wallet on the hook, and swap the hook itself with file(). On Solana the mint defaults new accounts to frozen and one program address holds the mint, freeze, and permanent-delegate authorities; no ACRDX was minted there on 2026-09-23. On 2026-09-23 most supply sat on Plume (20.3 million) and Monad (9.8 million), with 237,533 on Ethereum and 97,932 on OP Mainnet. Monad’s contract has no verified code, so its controls are not read.

Comparison and decision

ACRDX and Securitize’s ACRED, filed here as adverse, wrap the same Apollo fund. ACRDX is offshore-only where ACRED is for US accredited investors; both are BVI companies that hold the Apollo shares and issue their own shares as tokens. The comparison that decides is the same as for ACRED: bought directly, Apollo Diversified Credit Fund is a registered fund with a prospectus and the same quarterly exit. ACRDX adds a BVI company, a 0.50% fee, a 500,000 USDC minimum, and a register whose keys can freeze and move balances, and it bars US persons. Its register and holdings are more open than most tokenized credit, which is to its credit. The assessment is adverse, the program is excluded by policy because US persons may not hold it, and it is ineligible for model clients.

Sources

The claims above trace to these. Where a number could not be independently verified, the thesis says so.

• Centrifuge pool metadata for ACRDX (pool 281474976710664) · primary · accessed 2026-09-23
  Supports: issuer, eligibility, minimum, quarterly liquidity, holdings July 20, 2026, service providers, returns to June 30, 2026
• Anemoy Capital SPC Limited, ACRDX fact sheet, June 2026 · primary · accessed 2026-09-23
  Supports: BVI professional fund, CRDIX target, 43M USDC AUM, 0.50% fee, repurchases set by Apollo
• Centrifuge Docs, full-text export · primary · accessed 2026-09-23
  Supports: ACRDX addresses by chain, transfer hooks, account freezing
• Apollo Diversified Credit Fund prospectus · primary · accessed 2026-09-23
  Supports: interval fund, quarterly repurchase offers, credit mandate
• Verified FullRestrictions hook on Ethereum (Blockscout) · primary · accessed 2026-09-23
  Supports: members only, freeze
• Centrifuge Root on Ethereum (Blockscout) · primary · accessed 2026-09-23
  Supports: 48-hour delay, ward of the token and hook

Inherited controls

The research above describes the protocol layer. Every position also inherits the asset it holds and the chain it settles on. The most administered layer sets the position’s effective control grade; that is a control description, not a quality or suitability score.