Etherfuse Stablebonds (CETES, USTRY, TESOURO, KTB, GILTS, EUROB)

Research, firm shelf, model-client eligibility, and advisor selection are recorded separately. The scheduled date is the outside bound; new evidence can reopen the file sooner.

A Stablebond is not a bond. It is a claim against a small Mexican company, Etherfuse MX, on the nominal value of government bonds that company buys with the holder’s money and keeps in its own accounts at Mexican brokers. The token is issued by a sister company, Etherfuse Liquid MX, as a ledger-based security under Swiss law, with each bond’s Solana mint as the register. Six bonds are live: Mexican CETES, US Treasuries (USTRY), Brazilian Tesouro, Korean KTB, UK gilts and euro bonds. On 23 September 2026 Etherfuse’s own feed put them at about $18 million, $12.4 million of it USTRY and $4.8 million CETES. The holder’s protection is contract and Mexican insolvency law, not a trust, a fund or a regulator. Mexico’s securities regulator told Etherfuse in 2024 that the tokens are not securities and that the business needs no licence; the customer agreement says no Mexican financial authority supervises it. The bonds are not held in the holders’ names. If Etherfuse fails, holders must go to a Mexican court and ask to separate the assets from the estate. We reject it. The holder terms bar US persons, which ends the question for our clients. Apart from access, a holder takes the credit risk of an unsupervised company, the currency risk of the bond, and control keys that sit with Etherfuse: a 3-of-5 multisig can upgrade every EVM copy, and one key can upgrade the Solana programs that mint.

Research triggers: events that reopen the assessment or shelf decision
• Etherfuse opens the Stablebonds to US persons under a registration or exemption
• Etherfuse moves the bonds into a trust, fund or segregated account in the holders’ name, or a regulator takes on supervision
• An attestation shows reserves below the tokens in issue, or attestations stop
• The Solana program upgrade key, the Stellar issuer flags, or the EVM owner Safe changes
• The customer agreement or a registration agreement is replaced

The research file

What a holder owns

Two contracts define the product. The customer agreement, between the customer, Etherfuse MX, S.A. de C.V. and Etherfuse Liquid MX, says the money a customer pays is received ”in administration,” that Etherfuse MX uses it to buy the bonds the customer picks, and that Etherfuse MX ”grants the Customer the individual credit right on nominal value of the Securities that are acquired.” The claim is paid two ways: as ”Rewards,” the yield Etherfuse passes on, which shows up as a rising token price, and at the end of the last payment period as the bond’s nominal value, which Etherfuse must send to the holder’s wallet within three business days. The Stablebonds overview says the token is ”a proportional economic claim” on a pool, valued at NAV and not pegged: one CETES token was worth MXN 1.18 that day.

The second contract is a Swiss registration agreement for each bond, prepared by MME Legal in Zurich and linked from each Solana mint’s metadata. It names Etherfuse Liquid MX, S.A.P.I. de C.V. as issuer and Etherfuse MX as administrator of the ledger, and says the Solana mint is the register under article 973d of the Swiss Code of Obligations: ”The entitlement to the securitized Instruments exclusively results from the Securities Ledger.” Swiss law governs the token’s form and transfer; the claim itself stays under Mexican law. MME’s own letter of 8 April 2025, addressed to Etherfuse Inc of Irvine, California, says this is ”feasible” provided the terms and the smart contract comply, and states that MME did no independent check. The registration agreement names only the Solana mints. It is silent on the Stellar, Base, Polygon and Monad copies, which carry most of the value: 11.51 million of the 11.52 million USTRY sit on Stellar.

The documents do not agree on who issues. The customer agreement defines the token as issued by Etherfuse Liquid; the legal FAQ calls the Stablebonds ”Tokens issued by Etherfuse®,” which it defines as Etherfuse MX. The holder’s money claim runs against Etherfuse MX either way.

Where the bonds are, and what happens if Etherfuse fails

Etherfuse says the bonds sit at BBVA México, Actinver Casa de Bolsa and Kuspit Casa de Bolsa under brokerage agreements in Etherfuse’s name, and that CETES are held through Indeval, Mexico’s securities depository. Its product page says instead that each bond is held ”in the home country of the issuer.” The two cannot both be right for gilts, Korean bonds or Treasuries, and neither page names a custodian outside Mexico. An independent firm, not named on the page, attests from time to time that reserves match the tokens in issue.

Etherfuse’s bankruptcy argument is this. Because it receives the money in administration under a commercial mandate and never takes ownership, article 70 of Mexico’s insolvency law lets a customer bring a separation action and pull the assets out of the estate before creditors are paid. The agreement forbids Etherfuse to lend or pledge the money. That is a real legal route, but it is a lawsuit a holder must bring in Mexico City, over assets held in Etherfuse’s accounts rather than in the holder’s name, and the customer is also listed as a possible ”Common Creditor.” No trustee, security agent or segregated vehicle stands between the holder and the company.

On 16 April 2024 the CNBV, in Resolution P090/2024 to Etherfuse Liquid, found the tokens are neither credit titles nor securities under Mexican law and that the service needs no authorization. The customer agreement draws the conclusion plainly: neither the agreement nor Etherfuse Liquid is subject to CNBV supervision. Etherfuse offers the product in Mexico by ”reverse solicitation,” a private invitation.

Who may hold, and how a holder gets out

The holder terms are a Regulation S legend: ”The Holder is not a U.S. Person as defined in Rule 902(k) of Regulation S,” and ”the Company shall not register the transfer of the Tokens in violation of these restrictions.” The customer agreement also shuts out residents of FATF grey- and black-list countries, and Etherfuse checks every customer’s identity before opening an account. No purchase minimum is stated.

The contracts do not enforce any of this. There is no allowlist on any chain we read, so anyone can receive a Stablebond on a secondary market. What they cannot do without Etherfuse is get paid: the agreement says the claim ”may be exercised solely and exclusively by the new owner of the Token who complies with the terms and conditions for maintaining a contractual relationship” with Etherfuse. A token in an unverified wallet is a claim its holder cannot collect.

A verified customer exits by selling back to Etherfuse at NAV, which Etherfuse says it honors ”any business day,” for pesos paid to a Mexican bank account, the only live fiat rail, or by swapping for USDC. The ramp fee is 0.20% below $5 million a month. Etherfuse also keeps 0.25% to 1.5% of the bond yield, rising with the yield. On Base its guide tells integrators to sell at least about 50 CETES at a time, because gas is bundled into the fee and the fee may not exceed half the order. A holder of a peso, real or won token carries that currency against the dollar.

Control on chain

We read CETES on each chain on 23 September 2026. On Solana it is a Token-2022 mint with no freeze authority and no permanent delegate: no one can freeze or take a holder’s tokens. Its only extensions are an interest-bearing rate, set by a key of Etherfuse’s stablebond program, and a metadata pointer. The mint authority is a 1-of-2 SPL multisig (A6nFyQb2…) whose two signers are accounts of two Solana programs, one of them Etherfuse’s stablebond program, and both programs can be upgraded by the same ordinary key (FAGLBF88…). One signature can therefore change the code that decides when new tokens are minted. The registration agreement lists freezing as ”n/a” but lets the administrator ”pause all transactions” during a technological change.

On Stellar the issuer account (GCRYUGD5…) has no authorization, revocation or clawback flag set, so it cannot freeze a trustline today. The flags are not locked, so the issuer could set them later for new trustlines. All six bonds share this one issuer account.

On Base, Polygon and Monad each bond is a LayerZero OFT behind an upgradeable proxy. The owner is a 3-of-5 Safe (0x14b92824…), which also controls the proxy admins. It can upgrade the code, choose which contracts on other chains may send tokens in, and set rate limits; it or a pauser it names can pause any bridge route. That pause stops tokens leaving the chain, not transfers between holders, but an EVM holder’s sale to Etherfuse bridges the tokens back, so a paused route also closes that exit. The Monad implementation is not verified, so we could not confirm its powers there.

Against the other tokenized treasuries on file

BUIDL, BENJI and WTGXX put a registered fund share on chain: a transfer agent keeps the record, the fund’s assets sit with a custodian in the fund’s name, and a US regulator supervises the manager. USDY and the Spiko funds use a note or a European fund with a security agent or depositary. Etherfuse has none of these layers. The holder lends to Etherfuse MX, which promises to hold bonds and pay them out, and the protection is that promise, a Mexican separation action and periodic attestations. The on-chain design is cleaner than most, with no freeze on Solana or Stellar, but the legal claim is weaker than any other treasury product on the Register.

Sources

The claims above trace to these. Where a number could not be independently verified, the thesis says so.

• Etherfuse (CETES) Registration Agreement, MME Legal (plain text) · primary · accessed 2026-09-23
  Supports: issuer Etherfuse Liquid MX; administrator Etherfuse MX, Solana mint is the ledger under CO 973d, freezing n/a; pause during technological change
• Etherfuse, Agreement for the Provision of Services and Commercialization of Tokens (plain text) · primary · accessed 2026-09-23
  Supports: credit right on nominal value, funds in administration; no lending, claim only by owner with a relationship, maturity payment within 3 business days, no CNBV supervision
• Etherfuse, Terms & Conditions (US securities-law restrictions) · primary · accessed 2026-09-23
  Supports: Regulation S; no US persons, transfers breaking the restrictions not registered
• Etherfuse legal overview: Asset Security · primary · accessed 2026-09-23
  Supports: BBVA México, Actinver, Kuspit, separation action under LCM art. 70, common creditor, unnamed attestor
• Etherfuse legal overview: Legal FAQs · primary · accessed 2026-09-23
  Supports: CNBV Resolution P090/2024, reverse solicitation, tokens issued by Etherfuse MX
• Etherfuse legal overview: Stablebonds Overview · primary · accessed 2026-09-23
  Supports: NAV claim, not pegged, fee 0.25% to 1.5% of yield
• MME Legal, Tokenization under Swiss law according to article 973d CO (8 April 2025) · primary · accessed 2026-09-23
  Supports: addressed to Etherfuse Inc, Irvine, feasible, subject to conditions, no independent verification
• Etherfuse: Stablebonds product page · primary · accessed 2026-09-23
  Supports: redeem at NAV any business day, custody in the home country of the issuer
• Etherfuse public API: stablebonds and token costs · primary · accessed 2026-09-23
  Supports: supply and NAV per bond and chain, about $18 million in total
• Etherfuse CETES token metadata (linked from the Solana mint) · primary · accessed 2026-09-23
  Supports: CETES held through Indeval, registration agreement linked on chain
• Etherfuse developer docs: Ramp Fees · primary · accessed 2026-09-23
  Supports: 20 bps below $5 million a month, Mexico the only live fiat rail
• Etherfuse developer docs: Base · primary · accessed 2026-09-23
  Supports: offramp at least about 50 CETES
• Stablebond OFT implementation on Base (Sourcify exact match) · primary · accessed 2026-09-23
  Supports: LayerZero OFT, pause blocks outbound routes only, owner sets peers and rate limits

Inherited controls

The research above describes the protocol layer. Every position also inherits the asset it holds and the chain it settles on. The most administered layer sets the position’s effective control grade; that is a control description, not a quality or suitability score.