Delta Wellington Ultra Short Treasury On-Chain Fund (ULTRA)
Review open since 2026-09-29: Delta Wellington Ultra Short Treasury On-Chain Fund (ULTRA) on Ethereum: Admin role gained a holder: 0xa9a5e596e7e27b42c9cfe2d933db930867ee680d, a single key (RoleGranted logged at block 26074163, tx 0x49ccc472df159df9dd0c7c6f13a3c509dd40c803956656c15f8e25871fdf8af2) (read at block 26075774). Ketju will review the file before any client action. A draft revision dated 2026-09-29 is under audit and would change the assessment. The verdict stands until the review closes.
Summary
Ketju does not approve ULTRA: the fund has shrunk to about $7 million, one private key can replace the token’s code, and every transfer between holders waits for an off-chain release. ULTRA is a unit of a sub-fund of the Delta Master Trust, a Singapore unit trust. FundBridge Capital manages it, and Wellington Management picks the bonds. Perpetual (Asia) is trustee, Standard Chartered holds the assets, and Vistra keeps the books. Libeara, a Standard Chartered company, runs the token contracts. We found no defect in the service providers. Libeara claimed $195 million in December 2025; rwa.xyz showed about $7 million on 2026-09-24. Only qualified purchasers may buy, with a $200,000 minimum. A client who is a qualified purchaser can hold US Treasury funds with larger books and published documents.
- FundBridge publishes the information memorandum and trust deed, and they settle which register governs
- The default admin, super admin, and operator admin roles move to a multisig with a delay on every chain
- The transfer limit rises so that holders can move units without an off-chain release
- The fund’s units outstanding return above $100 million across the chains read
Ketju checks this memo every night. A review opened on 2026-09-29 and appears under the verdict above. The verdict stands until the review closes.
Research
How it works
FundBridge’s application to the Arbitrum DAO’s STEP 2 program, filed in March 2025, gives the fullest public account. ULTRA is the second sub-fund of the Delta Master Trust, an open-ended umbrella unit trust; the first was an SGD fund. ULTRA invests in US Treasury securities with less than a year to run. It may hold repos, reverse repos and cash. It aims to beat the ICE BofA 3-Month Treasury Bill Index on a total-return basis.
Each sub-fund is a separate trust, and the trustee holds its assets for its unitholders. The custodian must keep them apart from its own assets. Income stays in the fund, so the unit price rises: DefiLlama priced a unit at $1.0573 on 2026-09-24. FundBridge gave the information memorandum, trust deed and subscription agreement to the DAO privately, and they are not public. The fund’s own page on Libeara’s microsite requires a password.
Size and holdings
The first sale was on 19 February 2025. The Form D amendment of 3 November 2025 reports $135,341,364 sold to seven investors. Libeara said on 11 December 2025 that ULTRA had “over US$195 million” across Ethereum, Arbitrum and Avalanche. It named Theo as the anchor investor on Solana.
On 2026-09-24 the Ethereum contract carried 797,543 units and the Arbitrum contract 980,358, about $1.9 million together. rwa.xyz also counts 4.84 million units on Solana. It shows 6.61 million units worth $6.99 million, down 79% in thirty days, held by fifteen wallets. The fund is therefore a small fraction of what its sponsors described nine months earlier. Theo sells its thBILL as exposure to ULTRA. On 2026-09-23 Theo booked 35.7 million of ULTRA as “pending,” and that figure does not appear in the units outstanding.
Eligibility
Libeara’s microsite directs the trust “exclusively at accredited investors and institutional investors as defined under the Securities and Futures Act 2001 of Singapore.” The Form D claims Rule 506(c) and section 3(c)(7). Section 3(c)(7) admits only qualified purchasers, so a US holder must be one. Investors complete KYC with FundBridge, and FundBridge’s approval puts the wallet on the contract’s whitelist. The minimum is $200,000 in both the Form D and the application. FundBridge lets units pass between whitelisted holders “subject to the Manager’s approval.”
Withdrawals
Investors subscribe in USDC through an on- and off-ramp provider, or by dollar wire. Vistra checks the cash, and the contract then mints units. Redemption works in reverse: the holder sends units to the fund’s contract. FundBridge says it “offers daily redemptions on trading days, with settlement processed within 1-2 business days.”
Who controls it
On Ethereum and Arbitrum, ULTRA is an upgradeable ERC-20. Its verified code sends every transfer through a KYC contract, and both wallets must be approved unless the tokens go to the clawback wallet. Four roles run the token. On both chains a plain address, one private key, holds each role. The default admin, 0x3d5d…35bc, can replace the token’s code. The super admin, 0x0af4…7505, can take any balance into a wallet it chooses. The operator admin, 0x2038…cd92, can replace the KYC contract and set the transfer limit. Another plain address and several contracts hold the minter role.
FundBridge says every mint, burn and whitelist change needs its approval in Fireblocks’ MPC app. A key split that way still signs as one address, and that is what the chain shows. The contract has no freeze or pause function. However, FundBridge says the administrator can blacklist a holder, and a wallet off the KYC list can neither send nor receive.
The transfer limit is zero on both chains. Any transfer with a dollar value therefore goes into the manager contract as a “transfer promise.” It reaches the recipient only when an off-chain service releases it. No public document names the Solana mint, so we did not read it. Avalanche shows no units.
Comparison
Ketju compares ULTRA with the tokenized US Treasury funds for qualified purchasers that it has already reviewed. Those funds publish their terms and hold far more money. Any client can also buy a registered government money fund under a prospectus. ULTRA offers a Singapore trust with sound custody and a Wellington mandate. However, its documents are private, and its on-chain units have fallen to a few million dollars. One key can rewrite the contract, and a holder cannot move units without an off-chain release. A client who is not a qualified purchaser does not qualify to hold it.
Sources
Each claim above comes from one of these sources. Where Ketju could not verify a number, the memo states that.
- SEC EDGAR: Delta Wellington Ultra Short Treasury On-Chain Fund, Form D/A (2025-11-03) · primary · accessed 2026-09-24
Supports: Rule 506(c), section 3(c)(7), $200,000 minimum, $135.3M sold to seven investors, first sale 2025-02-19 - FundBridge Capital, ULTRA STEP 2 application (Internet Archive copy of 2025-03-22) · primary · accessed 2026-09-24
Supports: service providers, strategy and benchmark, bankruptcy remoteness, redemption timing, Vistra register copy, Fireblocks MPC approvals, blacklist and clawback - Libeara funds microsite: Delta Master Trust · primary · accessed 2026-09-24
Supports: accredited and institutional investors under the SFA, current ratings - Libeara: ULTRA and MG999 on Solana (2025-12-11) · primary · accessed 2026-09-24
Supports: over US$195 million AUM claim, Theo as Solana anchor investor - Verified ULTRA implementation Ultra.sol on Ethereum (Sourcify) · primary · accessed 2026-09-24
Supports: KYC check, clawback, transfer promises, role-gated upgrade - rwa.xyz: ULTRA · secondary · accessed 2026-09-24
Supports: $6.99M total value, units by chain including Solana, fifteen holders, 79% thirty-day decline
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. |
| Arbitrum One | Approved with limits | Mixed control | a single sequencer orders more than 99% of transactions, and admin keys can upgrade bridge contracts on a timelock of about 7 days. |