Anemoy Tokenized Apollo Diversified Credit Fund (ACRDX)

Summary

Ketju does not approve ACRDX: it holds the same Apollo credit fund that a client could buy directly, with the same quarterly repurchases, and adds an offshore company, a second fee and keys that can freeze and move balances. US persons may not hold it. ACRDX is a share of a British Virgin Islands fund that owns shares of Apollo Diversified Credit Fund, a US interval fund that lends to companies and against assets. Anemoy Capital SPC Limited runs it as a separate segregated portfolio. Anemoy is the Centrifuge-affiliated BVI professional fund that also issues JTRSY and JAAA. The holdings that Anemoy published on 20 July 2026 show 1,386,827 Apollo fund shares worth $30.7 million. We found no defect in how the fund itself works.

Review triggers
• Anemoy opens ACRDX to US investors under a published exemption, or publishes an offering memorandum that changes the investor class or the redemption terms
• 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

Ketju checks this memo every night and opens a review if its venues or files show a warning or a cited document changes. The first confirmation is due 2026-12-23.

Research

How it works

Anemoy says the fund “issues its shares as the ACRDX token to investors,” so the token is the share. Centrifuge holds the share register. 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.” Apollo’s fund is a registered closed-end interval fund. It mixes corporate direct lending, asset-backed lending, and performing and dislocated credit. It redeems shares 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 anyone can check the Apollo position against the tokens outstanding.

Size and holdings

The July holdings table lists CUSIP 39822Y307 at $22.11 a share: 1,386,827 Apollo fund shares worth $30.7 million, plus $0.5 million in a Western Asset liquidity fund. The fact sheet gives 43 million USDC of assets at 29 June. 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.

Fees

Anemoy charges a 0.50% management fee on top of Apollo’s own costs. Since its October 2025 launch, the fund has returned 2.64% a year.

Eligibility

The pool sheet and fact sheet state “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. We confirmed this by querying the hook on 2026-09-23.

Withdrawals

Anemoy takes subscriptions daily in USDC, USDS, AUSD or USDT. Redemptions are “subject to the timing of repurchases offered by the underlying Apollo Diversified Credit Fund.” Anemoy can pay out only when Apollo makes a quarterly repurchase offer, so the fund’s liquidity is Apollo’s. If Apollo prorates a tender, Anemoy prorates ACRDX holders too. There is no secondary market, because the hook blocks transfers to non-members.

Who controls it

On each EVM chain, three contracts are wards of the ACRDX token. Centrifuge’s Root contract acts only after a 48-hour delay. The Spoke and BalanceSheet contracts carry out the instructions that the pool manager sends from the Centrifuge hub. Through them the pool manager can mint tokens and move a balance with authTransferFrom. It can freeze a wallet on the hook and replace the hook itself with file(). On Solana, the mint sets new accounts to frozen by default. One program address holds the mint, freeze and permanent-delegate authorities there, and no ACRDX was minted on Solana on 2026-09-23. Monad’s contract has no verified code, so we did not read its controls.

Comparison

ACRDX and Securitize’s ACRED wrap the same Apollo fund, and Ketju does not approve ACRED either. ACRDX is only for investors outside the US, and ACRED is for US accredited investors. Both are BVI companies that hold the Apollo shares and issue their own shares as tokens. A client can buy Apollo Diversified Credit Fund directly as a registered fund, with a prospectus and the same quarterly repurchases. ACRDX adds a BVI company, a 0.50% fee, a 500,000 USDC minimum and a register whose keys can freeze and move balances. It also bars US persons. Anemoy publishes its register and holdings more openly than most tokenized credit programs do. Because US persons may not hold ACRDX, US clients do not qualify.

Sources

Each claim above comes from one of these sources. Where Ketju could not verify a number, the memo states that.

• 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

The asset and the chain

This memo covers the protocol. A position also holds an asset and settles on a chain. Whichever of the three holds the most power over the position decides who can freeze it. These tables describe control and do not judge quality.