BNY Dreyfus On-Chain Liquidity Fund (BCLXX), BLIQUID token
Review open since 2026-09-26: Open item: Re-read the bny-dreyfus-onchain-liquidity eligibility file: its issuer documents changed. A draft revision dated 2026-09-26 is under audit. The verdict stands until the review closes.
Summary
Ketju does not approve BLIQUID: the fund admits no individuals or retirement plans, and BNY publishes no contract address, so nobody can check its controls on chain. We found no defect in how the fund works. BLIQUID is a share of BNY Dreyfus On-Chain Liquidity Fund, a registered government money market fund whose share register is the chain. The fund is a series of Dreyfus Government Cash Management Funds. BNY Mellon Investment Adviser runs it, with Dreyfus as sub-adviser. The fund launched on 4 August 2026 with one $25 million subscription from one record holder, reported as a broker-dealer. It had no other flow through 31 August. An advisor who wants a Dreyfus government money fund for a client can hold one in an ordinary account.
- BNY publishes the BLIQUID contract address on Ethereum or Solana and the controls read on chain match the prospectus and Schedule H
- The fund admits individuals, or a broker-dealer or adviser offers the shares in fully disclosed accounts a household can open
- A second holder appears in the N-MFP3 and net assets move away from the one $25 million subscription
- BNY allows a holder-kept wallet, or accepts wallet providers beyond Anchorage Digital, BitGo, and BNY
Ketju checks this memo every night. A review opened on 2026-09-26 and appears under the verdict above. The verdict stands until the review closes.
Research
How it works
BLIQUID is a share of a government money market fund under Rule 2a-7. The fund values its holdings at amortized cost and prices its shares to hold $1.00. It holds Treasury securities with 93 days or less to run, overnight repos collateralized only by Treasuries and cash, and cash. It does not hold stablecoins or any digital asset. Each share is one BLIQUID token on Ethereum or Solana. BNY built the fund for stablecoin issuers to hold as reserves under the GENIUS Act, and for institutions.
The fund declares dividends at each NAV and pays them monthly. It reinvests them unless the holder asks for cash, and on reinvestment the transfer agent updates the token balance. The fund strikes NAV every hour from 8 a.m. to 5 p.m. Eastern on days it is open. The board may change this to once a day.
Share register
BNY Mellon Transfer, Inc., an SEC-registered transfer agent, keeps the register through its sub-transfer agent, BNY Mellon Investment Servicing (US) Inc. The prospectus says the blockchain entries “constitute the Transfer Agent’s official records of share ownership.” It calls the token a “book-entry token” and says a transfer on chain “results in a near real-time transfer of record ownership” of the share. The transfer agent keeps a duplicate off-chain copy and reconciles the two at least daily. If it cannot reconcile a discrepancy, the chain controls, and the transfer agent adjusts the off-chain copy.
The amendment to the transfer-agency agreement was signed on 27 July 2026 and filed on 25 September. It names the fund as the only “Digital Fund” on Schedule G. Schedule H defines the Master Shareholder Registry so that for digital shares it “is represented by the Book-Entry Token.” The amendment also states that the tokens “do not represent a separate or derivative security.” It states that no custody relationship arises between the transfer agent and a holder, and that the smart contracts “are owned solely by BNYMTI.” BlackRock’s BRSRV uses the same model, in which the issuer’s chain entries are the register.
Size and holdings
A supplement dated 24 July 2026 said BNY was not yet offering shares. BNY announced the launch on 4 August. The August N-MFP3 shows one subscription of $25,000,000 on 3 August 2026 and no other purchase or redemption through 31 August. On 31 August net assets were $25,000,000 and the portfolio $27.4 million. The only beneficial-owner category reported is “Broker-dealer,” which holds all the shares.
The same filing shows eight Treasury bills and one tri-party repo, cleared through the Fixed Income Clearing Corporation with Northern Trust. The weighted average maturity was 16 days, and the seven-day net yield was 3.48 percent on 31 August. BNY’s release says it expects its LiquidityDirect portal to support the fund, and press reports name BitGo as a launch partner. The fund is seven weeks old with one holder, so that holder decides its size.
Fees
The management fee is 0.20 percent. Total expenses are 0.42 percent before a waiver and 0.23 percent after it. BNY Mellon Investment Adviser has agreed to keep the waiver until 31 July 2027.
Who controls it
No contract address is public. The prospectus, the summary prospectus, the SAI, the transfer-agency amendment, BNY’s launch release, and Dreyfus’s BLIQUID page and brochure name no address on either chain. As of 25 September 2026, no explorer, rwa.xyz or DefiLlama listing ties a token to the fund.
The documents describe what the contracts do. They allow transfers only between allow-listed wallets on the same chain. They freeze tokens when a redemption order arrives and then remove them. They can “claw back book-entry tokens in the event of an unauthorized transfer.” Under Schedule H, BNY Mellon Transfer can freeze, cancel, correct, amend, mint, burn and reissue tokens for errors, security incidents, sanctions or bankruptcy. It can also reject and reverse a transfer.
The transfer agent may amend the Digital Share Procedures, including the transfer validation mode and the supported chains, without the fund’s consent. It must give thirty days’ notice of a material change. If the chain and its books diverge beyond reconciliation, or the law bars the digital shares, it may convert them to ordinary shares and burn the tokens. Until BNY publishes an address, nobody can check any of this against the code.
Eligibility
The fund admits stablecoin issuers, and institutions that act for themselves or through a bank, broker-dealer or adviser in a fully disclosed account. The prospectus says shares “are generally not eligible for retirement plans or individual investors.” The minimum is $3,000 for the first and each later investment.
A holder opens an account with the transfer agent and then registers a wallet through the Portal. A provider that the transfer agent accepts must keep the wallet, so the holder never holds the key. The transfer agent does not support self-custody. The launch release names Anchorage Digital, BitGo Bank & Trust and BNY as wallet providers.
Withdrawals
Holders may place orders at any hour, and the fund processes them when it is open. The fund normally wires a redemption in federal funds the same day, if it accepts the request by the last NAV of the day. In stress, proceeds may take up to seven days, and the fund may pay in securities. Wallet providers may convert the dollars to stablecoins outside the fund. The documents describe redemption by sending tokens to a burn address, but BNY does not offer it yet.
Holders may also transfer tokens to another allow-listed wallet on the same chain at any hour, at any price they agree. The fund arranges no market, and the transfer agent may reverse a transfer.
Comparison
Fidelity’s FDIT keeps the chain as a copy of its register. BLIQUID makes the chain the register, lets holders transfer to each other, and asks $3,000 to open against $1,000,000. We judge BLIQUID the stronger design of the two. BlackRock’s BRSRV also makes the chain the register, and like BRSRV, BLIQUID publishes no contract address and has one holder. Franklin’s BENJI is the only registered on-chain money fund open to individuals. BLIQUID admits no individual and no wallet that the holder keeps.
BNY is a sound sponsor. The fund is a registered 2a-7 fund, and its prospectus states its terms in full. Against that, nobody can read the contract, the register is seven weeks old, and the fund has one holder. Individuals may not hold it, so household 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.
- SEC EDGAR: BNY Dreyfus On-Chain Liquidity Fund prospectus and SAI dated 24 July 2026 (497, filed 29 July 2026) · primary · accessed 2026-09-25
Supports: government money market fund, blockchain entries are the official record, daily reconciliation, Ethereum and Solana, custodial wallets only, stablecoin issuers and institutions, not for individuals, $3,000 minimum, hourly NAV, same-day wire, freeze and clawback, peer-to-peer transfer, fees and waiver, dividends - SEC EDGAR: Amendment No. 2 to the BNY Mellon Transfer, Inc. transfer agency agreement, Schedule H Digital Share Services (filed 25 September 2026) · primary · accessed 2026-09-25
Supports: only Digital Fund on Schedule G, registry represented by the token, not a separate security, freeze, cancel, mint, burn, reissue, contracts owned by BNYMTI, procedures amendable without consent, conversion to standard shares - SEC EDGAR: Dreyfus Government Cash Management Funds, Post-Effective Amendment No. 88 (POS EX, filed 15 September 2026) · primary · accessed 2026-09-25
Supports: registration file numbers, certificate of designation, agreements amended 26 May 2026 - SEC EDGAR: prospectus supplement dated 24 July 2026 (497) · primary · accessed 2026-09-25
Supports: shares not offered on 24 July 2026 - SEC EDGAR: Form N-MFP3 for BNY Dreyfus On-Chain Liquidity Fund, August 2026 · primary · accessed 2026-09-25
Supports: $25,000,000 net assets, one subscription on 3 August 2026, broker-dealer holder category, holdings, WAM 16 days, seven-day net yield 3.48% - BNY Investments: BNY Investments Launches Its First Native Blockchain Product, BLIQUID by BNY (4 August 2026) · primary · accessed 2026-09-25
Supports: launch date, Anchorage Digital, BitGo, and BNY as wallet providers, shares issued natively on chain, LiquidityDirect - Dreyfus: Digital Liquidity Solutions (BLIQUID page) · primary · accessed 2026-09-25
Supports: one token is one share, 24/7 transfers, institutional investors only
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.
| Chain | Verdict | Freeze | What it can do |
|---|---|---|---|
| Ethereum | Approved | No freeze key | Ethereum has no sequencer, no upgrade key and no operator who can be compelled to act; rule changes require social consensus. |
| Solana | Approved with limits | Governed, no freeze | no admin key can seize funds, but stake is concentrating and the Nakamoto coefficient is below 25. |