Spiko Digital Assets Cash and Carry Fund (SPKCC, eurSPKCC)

Summary

Ketju does not approve the Spiko Digital Assets Cash and Carry Fund: every buyer must certify it is not a U.S. person under Regulation S, and that definition covers any discretionary account a U.S. adviser holds, even for a foreign client. The prospectus, updated 1 February 2026, calls the fund a French professional specialized fund (fonds professionnel spécialisé, or FPS) “that is not authorized by the French Financial Markets Authority (AMF).” It is a standalone FCP outside the Spiko SICAV, so the SICAV memo’s terms do not apply. Twenty First Capital keeps the register, and the first subscription is at least EUR 100,000. The fund buys a certificate from Marex that pays the return of an index Marex owns: long spot Bitcoin or Ether, short the nearest CME future, or cash when the futures premium is too thin. The holder’s return therefore depends on Marex paying. Spiko’s fee page lists a 1% note cost that the key information document leaves out, and the manager takes 25% of any return above SOFR or €STR. We could not settle the research, because the fund documents do not publish the certificate’s terms: whether Marex posts collateral, when it may end the note early, and which Marex entity owes the money. Spiko’s own pages also disagree with the published index rules on which coins the strategy trades.

Review triggers
• Twenty First Capital opens the fund to U.S. persons or changes the Regulation S definition it applies
• Spiko or Twenty First Capital publishes the Marex certificate’s terms, including collateral, early termination, and the issuing entity
• Marex defaults on or terminates the certificate, or the fund adds a second counterparty
• Compass publishes a methodology that adds coins beyond Bitcoin and Ether, or Spiko corrects its product page
• The fund uses its 10% redemption cap, suspends its NAV, or its net assets fall toward €300,000
• The implementation or permission-manager authority of any share contract changes, the burner group changes, or a freeze function is added
• Any AMF action against the fund, Twenty First Capital, or Spiko Finance

Ketju checks this memo every night. A review opened on 2026-10-05 and appears under the verdict above. The verdict stands until the review closes.

Changes

Research

How it works

A SPKCC token is a USD share (ISIN FR0014010OM9) of the Spiko Digital Assets Cash and Carry Fund; eurSPKCC is the EUR share (FR0014010ON7), hedged to euros with currency forwards. The fund is an FCP, a co-ownership of assets with no legal person of its own, set up on 24 July 2025 for 99 years and registered with the AMF on 21 July 2025. An FPS files with the AMF, but the AMF does not authorize it. It is “not subject to any investment rules set by regulations,” and the management company may amend its rules with three business days’ notice. The prospectus says the shares “are registered in the designated DLTs and are not admitted to Euroclear France,” so the token balances are the share register. Twenty First Capital keeps that register “through a platform provided by SPIKO FINANCE.” CACEIS Bank is depositary and CACEIS Fund Administration computes the NAV; PwC audits. The shares carry no voting rights and reinvest all income. There is no guarantee, no deposit insurance, and no SIPC.

Strategy

A futures contract on Bitcoin usually trades above spot because a buyer of the future gets exposure without paying the full price. A trader who buys spot and sells the future earns that gap, and the gap closes as the contract nears expiry because the future settles to the spot price. Compass Financial Technologies calculates the Spiko Digital Assets Cash and Carry Index (SPKCARRY), which Marex owns; the index tracks that trade without holding coins. Once a month the index rules measure the premium of the nearest CME Bitcoin and Ether futures over spot, subtract what SOFR would earn over the same days, and go long spot and short futures in whichever coin beats the other and a 0.40% threshold. If neither coin beats it, the index holds a SOFR money market position. It holds the position until two business days before the contract’s last trading day, rolls over those two days, and starts again. While the trade is on, the index earns the basis and nothing on the notional: its rules charge 0.10% to trade spot, 0.10% a year for custody, financing on a 35% initial margin at SOFR plus 2.85%, and 0.35% a year on variation margin. Compass published a level of 167.921 on 22 September 2026 from 100 on 6 January 2020, 8.02% a year with 1.15% volatility, though Compass first published the index in June 2025 and the earlier years are back-calculated. The fund holds the certificate and, for cash, US government bills; the prospectus says it “will under no circumstances invest in digital assets” as French law defines them. Marex runs the actual hedge. The fund documents do not say where the spot coins sit; the prospectus says only that the fund lacks “details about storage, service providers used for trading, or the ‘private keys’” needed to move them.

Losses and incidents

Holders could lose money in four ways. First, the gap can widen before it closes. If traders bid the future up mid-month, the short future loses more than the spot position gains and the NAV falls; Spiko’s product page says this can exceed 1% in a day. A holder who redeems then takes the loss. Second, the index leaves each contract two days early, so it keeps only the part of the basis that has closed by then, and the next contract may open at a worse premium. Third, the fund pays margin financing, the note cost and the fees whether or not the basis pays. Fourth, and largest, Marex could fail to pay. Spiko’s FAQ says “capital is at risk if Marex defaults on its certificate,” and names Marex as the fund’s sole counterparty. The prospectus allows collateral agreements but publishes none for this note, and the fund is not bound by diversification rules. The key information document rates the fund 2 of 7 yet shows a stress case of $7,838 from $10,000 after a year, a 21.62% loss, and an unfavorable case of minus 1.91%. The EUR share adds the gap between a forward hedge and the dollar portfolio it hedges.

Fees

The prospectus fee table shows no management fee, operating costs capped at 0.10%, no indirect fees, and a performance fee of 25% of annual return above SOFR for the USD share or €STR for the EUR share, with a five-year catch-up on underperformance. Spiko’s documentation adds a “MAREX note cost” of 1.00% a year. That cost sits inside the certificate’s price, so the key information document shows total yearly costs of 0.10% and never mentions it. An adviser comparing this fund with a Treasury fund on the KID alone would miss a full point. Spiko’s pages contain two further errors. The product page gives FR001400ODM9 as the USD share’s ISIN; that is the Spiko US T-Bills fund’s code, and this fund’s code is FR0014010OM9. The page also says the strategy “currently follows 1-month futures contracts on BTC, ETH, SOL, and XRP,” while the only published index rules, version 1.0 of June 2025, name Bitcoin and Ether alone. The index steering committee includes two people from Marex and two from Spiko, and a material change to the rules needs only two weeks’ notice.

Eligibility

The prospectus reserves the shares for investors listed in Article 423-27 of the AMF General Regulation and spells out who that means: professional clients under MiFID II, the management company and its staff, and “any other investors, provided that the minimum subscription is made in their name and on their behalf” by a firm managing their portfolio under mandate. Spiko’s product page says the fund “is open to individuals and companies” at the minimum. A retail buyer therefore qualifies through the size of the subscription: a first subscription of EUR 100,000 (USD 114,110 at the ECB rate of 23 September 2026), then 1 USD or 1 EUR. Spiko says it does not market the fund outside France. Transfers happen privately and only to an address the management company has already allowlisted; the fund books each one as a redemption and a new subscription, and the fund regulations require a new holder to top up to the minimum. Every buyer certifies it is not a U.S. person, and the prospectus’s footnote counts “any discretionary account … held by a financial intermediary … organized, incorporated, or (in the case of a natural person) resident in the United States of America.”

Withdrawals

Redemption orders reach the management company by 11:00 a.m. Paris on day D-1. The NAV is calculated on D from D-1 market data, and cash pays on D+1: Spiko’s documentation calls this D+2. No NAV is struck when France, the UK, or the US is on holiday, or when TARGET or the CME is closed. Redemptions pay in cash only. When net redemptions on one date pass 10% of the fund, the management company may cap them and carry the rest forward, for at most 20 NAVs in a month; carried orders cannot be withdrawn. It may also suspend issues and redemptions “when exceptional circumstances so require,” and no redemptions are allowed if net assets fall below €300,000. Unlike the SICAV’s bill funds, this fund has no instant-withdrawal service: Spiko’s terms of use describe that service for its UCITS funds.

Who controls it

SPKCC and eurSPKCC run the same code as Spiko’s SICAV shares. On Ethereum, Polygon, and Base the token proxies point at implementation 0x15ea…5f74, the one USTBL uses, and answer to the same permission manager, 0x3442…8472; on Arbitrum they use 0xa076…fc80 and 0xa925…829a, again the SICAV’s. We found the same functions as in the SICAV: an allowlist, a pause, a burn from a holder’s address, a role-gated mint, and an upgrade, with no freeze function. Spiko shares the permission manager’s groups across every Spiko token on a chain. A 3-of-6 multisig holds the admin and upgrade powers, and a 1-of-6 multisig can pause. The burner group holds the redemption contract plus contracts owned by a single key and one plain address. Spiko’s engineering post says only the redemption contract may burn, but the on-chain roles show other burners, for this fund as for the SICAV. The fund regulations give that burn a legal use: the management company may force-redeem an ineligible holder “after a period of 10 business days” at the last known NAV. Twenty First Capital is the legal register keeper. We could not tell from the chain whose people sign the multisigs, and the prospectus says only that Spiko provides the platform.

Comparison

The fund is about fourteen months old. CoinGecko listed eurSPKCC at about $31.4 million and SPKCC at about $6.0 million on 23 September 2026. Spiko’s product page claims $86 million to $123 million, and we could not reconcile the two sets of figures. We found no default, suspension, gate, or AMF action. Spiko discloses Marex’s role on its web pages; the prospectus names no counterparty. The Spiko SICAV’s bill funds have a UCITS rulebook, a one-unit minimum, and daily redemption with instant withdrawals. This fund instead is unauthorized, with a EUR 100,000 minimum, two-day redemption, a crypto basis, and one broker’s credit. Ethena-style on-chain basis products use perpetual swaps on crypto exchanges. This fund uses regulated CME futures and a French depositary, but it adds a certificate between the holder and the hedge. A US client cannot buy any of these; the comparable exposures are registered funds or CME-listed products held at a custodian.

Sources

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

• Spiko Digital Assets Cash and Carry Fund prospectus and fund regulations (English), updated 1 February 2026 · primary · accessed 2026-09-23
  Supports: FPS not authorized by the AMF, FCP created 24 July 2025, Article 423-27 investors, EUR 100,000 minimum, U.S. person definition, 11:00 a.m. cutoff, D+1 payment, 10% redemption cap, register kept by the management company on DLT, no voting rights, no direct digital assets, forced redemption, performance fee
• Prospectus du fonds et règlement (French), 1 February 2026 · primary · accessed 2026-09-23
  Supports: fonds professionnel spécialisé non agréé, article 423-27, règlement
• Key information document, USD share (1 February 2026) · primary · accessed 2026-09-23
  Supports: risk indicator 2 of 7, stress scenario minus 21.62%, total costs 0.10%, not marketed to U.S. persons
• Key information document, EUR hedged share (1 February 2026) · primary · accessed 2026-09-23
  Supports: EUR share hedged
• Spiko: Cash & Carry product page · primary · accessed 2026-09-23
  Supports: Marex sole counterparty, certificate issued by Marex, basis risk above 1% a day, BTC, ETH, SOL, XRP claim, USD ISIN misprint, assets claimed, not marketed outside France
• Spiko docs: What is a cash & carry strategy? · primary · accessed 2026-09-23
  Supports: monthly selection, CME nearest futures, Marex execution
• Spiko docs: Cash & Carry fee structure · primary · accessed 2026-09-23
  Supports: MAREX note cost 1.00%, performance fee 25%
• Spiko docs: Cash & Carry stakeholders · primary · accessed 2026-09-23
  Supports: CACEIS Bank, Marex note issuer, Compass, PwC
• Spiko docs: Cash & Carry fund share classes · primary · accessed 2026-09-23
  Supports: SPKCC and eurSPKCC, ISIN codes, D+2 liquidity
• Spiko docs: contract addresses and audits · primary · accessed 2026-09-23
  Supports: token contracts per chain, shared permission manager
• Compass Financial Technologies: SPKCARRY index methodology, version 1.0 (25 June 2025) · primary · accessed 2026-09-23
  Supports: long spot short CME futures, 0.40% threshold, roll two days before last trade, margin and custody costs, owned by Marex, steering committee
• Compass Financial Technologies: SPKCARRY index page · primary · accessed 2026-09-23
  Supports: index level 167.921, annualised return and volatility
• Spiko engineering blog: smart contract architecture · primary · accessed 2026-09-23
  Supports: permission-manager groups, burner role described as redemption contract only
• Légifrance: AMF General Regulation, Articles 423-27 to 423-32-3 · primary · accessed 2026-09-23
  Supports: FPS investor categories, EUR 100,000 initial subscription
• Spiko: Terms of Use · primary · accessed 2026-09-23
  Supports: instant withdrawal service for UCITS
• CoinGecko: Spiko Digital Assets Cash & Carry Fund · secondary · accessed 2026-09-23
  Supports: market capitalization

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.