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Tokenized real-world assets

BlackRock Select Treasury Based Liquidity Fund, OnChain Shares (DOLXX), BSTBL token

Not approved No defect found; not on the approved list
Verdict
Not approved
No defect found; not on the approved list
Who can freeze it
Protocol
The one key can mint, burn any holder’s tokens, freeze a wallet, pause every transfer and replace the code.
Withdrawals
The holder moves tokens to the fund’s Redemption Wallet by 5:00 p.m.
Reviewed
2026-09-23 · next 2026-12-22
Researched memo

Summary

Ketju does not approve BSTBL: we found no defect in how the fund works, but one ordinary key holds every power over the token, BlackRock does not publish the contract address, and the minimum is written for institutions. BSTBL is one share class of a large, long-running BlackRock money fund, issued on Ethereum. The fund is BlackRock Select Treasury Based Liquidity Fund, formerly BlackRock Liquid Federal Trust Fund. It is a registered government money market fund in the BlackRock Liquidity Funds trust and held $6.47 billion on 22 September 2026. On 31 July BlackRock added a class called OnChain Shares, ticker DOLXX. That class held $11.9 million on 22 September, all of it in one wallet. BNY Mellon Investment Servicing keeps the share register on chain. The one key can mint, burn any holder’s tokens, freeze a wallet, pause every transfer and replace the code.

Research

How it works

One BSTBL token is one OnChain Share of BlackRock Select Treasury Based Liquidity Fund. The fund is a series of BlackRock Liquidity Funds (1940 Act file 811-2354), and BlackRock Advisors manages it under Rule 2a-7. The OnChain class shares the fund’s portfolio with nine older classes sold through ordinary channels, such as Institutional Shares (TFFXX). BSTBL launched the same week as BRSRV, but it is a separate program. BRSRV is a new fund in a different trust, and Securitize keeps its register.

BNY Mellon Investment Servicing (US) Inc., an SEC-registered transfer agent (file 084-01761), “maintains the official record of ownership of OnChain Shares on a public blockchain.” It uses “a permissioned system that operates in connection with a public, permissionless blockchain.” The prospectus states that the chain records, joined to BNY’s list of who owns each wallet, “will constitute the official shareholder register.” The token is therefore the share. The shares are ERC-20 tokens on Ethereum only.

An investor fills in an account application and gives BNY a wallet address. BNY tells the investor when the wallet is “whitelisted.” BNY “retains the discretion to support only certain digital asset custodian wallets.” Orders go through BlackRock’s Cachematrix portal or the Liquidity Service Center by 5:00 p.m. Eastern. The investor must pay in federal funds by 6:45 p.m. BNY mints the tokens that day, and they cannot move until the next business day. The fund pays dividends each month as new tokens.

The chain shows the pattern. The token was created on 4 August 2026. From 6 August the owner key minted round lots of $390,000 to $2.5 million to one wallet, at about 22:46 UTC on business days, through a function named mintLockToken. On 1 September it minted 12,847.27 tokens, the August dividend reinvested as the prospectus describes. Supply on 23 September was 11,902,847.27, the $11.9 million class size that BlackRock reported the day before. BlackRock does not publish the contract address. We tie it to the fund by its on-chain name and by this supply. No token has yet been redeemed.

Size and holdings

The fund “invests 100% of its total assets in cash, U.S. Treasury bills, notes and other obligations” of the Treasury maturing in 93 days or less, and in overnight repo backed by them. On 22 September BlackRock showed a weighted average maturity of 20 days, a 7-day SEC yield of 3.69 percent and 100 percent weekly liquid assets. The fund is rated AAAm, AAAmmf and Aaa-mf. The CUSIP of the OnChain class is 09250C572. There is no deposit insurance and no SIPC cover.

Fees

The management fee is 0.20 percent. BlackRock caps total expenses at 0.17 percent through 30 June 2028.

Stablecoin reserves

A supplement dated 31 July adds a “Stablecoin Regulatory Risk” to the older classes’ prospectuses, and the OnChain prospectus carries it too. The fund “intends to operate such that its shares will be ‘eligible reserve assets’ for payment stablecoin issuers” under the GENIUS Act of July 2025. BlackRock says that buying only short Treasuries and overnight Treasury repo makes the shares eligible reserves. The same supplement removed other investment companies from what the fund may buy.

The prospectus warns of a risk if the rules exclude money fund shares, or if the OCC caps how much of an issuer’s reserves may sit in one product. Stablecoin holders “could be required to redeem their holdings,” and large redemptions could hurt the fund. The prospectus also expects many record owners to be trust accounts at crypto banks whose customers are stablecoin issuers. It says BlackRock may pay those banks from its own money.

Withdrawals

The holder moves tokens to the fund’s Redemption Wallet by 5:00 p.m. Eastern on a business day. BNY burns them that day. The fund “typically” wires federal funds the same day, or the next day the custodian is open. A transfer counts only once it is final on chain, so the prospectus tells holders to send early. A holder who cannot redeem on chain may call, and BNY then burns the tokens in the wallet. The prospectus states that redemptions do not depend on any chain working.

The shares have no listing. Holders may transfer tokens between whitelisted wallets at any hour, but these transfers “do not constitute a public trading market.” The shares will not trade on an exchange or an ATS. The fund may redeem an account worth less than $100,000 on 60 days’ notice. It may stop transfers between wallets if it suspends redemptions to liquidate.

Eligibility

The class is “only registered for sale in the United States and certain of its territories,” and the fund “generally does not accept investments from non-U.S. residents.” The minimum is “$3 million for institutions,” which the fund’s officers may reduce or waive. Later purchases have no minimum. The BRSRV prospectus spells out rules for natural persons. The BSTBL prospectus names no rule for individuals and no investor test. It publishes no list of states. An advisor to households would find nothing in it that bars a client, and nothing built for one. We have not decided whether a household client qualifies.

Who controls it

The token is an upgradeable proxy. The prospectus states that the contracts are “designed, deployed, and maintained by the Transfer Agent,” and the verified code is named FundBNRV1. We found an allowlist, a freeze, a pause, a burn that can take tokens from any holder, a mint and an upgrade path. The owner, 0x0fc1…5cea, controls every one of those functions. It is an ordinary address with no code, and it also deployed the token. The same address owns the proxy admin contract (0x628d…3909), which can replace the code. One private key therefore holds every power over the fund’s on-chain register.

The prospectus describes the powers without naming the key. The contracts support the “ability to claw back Tokens under certain circumstances.” The fund may “freeze shareholder wallets” for money laundering and sanctions reasons. If a holder loses a key, BNY may freeze the tokens and reissue them. Because the chain is the register, a burn by that key changes who owns the shares themselves.

Comparison

BRSRV is a new fund; BSTBL is a class of a large, long-running fund, and BNY replaces Securitize as transfer agent. Both have a $3 million minimum and a 5:00 p.m. cutoff, and both burn and wire the same day. BRSRV pays dividends daily as new tokens and runs on Ethereum, Solana and Tempo. BSTBL pays monthly and runs on Ethereum alone. BRSRV splits control between two keys, the token owner and the wallet registrar. BSTBL puts every power in one key. An ordinary government money fund held at a custodian lacks whitelisted transfers at any hour. BSTBL adds that feature and the risk that a key, a contract or the chain fails.

Sources

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

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.

ChainVerdictFreezeWhat it can do
EthereumApproved No freeze key Ethereum has no sequencer, no upgrade key and no operator who can be compelled to act; rule changes require social consensus.
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