Fidelity International USD Digital Liquidity Fund (FILQ-A, FILQ-D)

Summary

Ketju has not reached a verdict on FILQ: Fidelity International’s server refused our requests for the prospectus, so we have not read its U.S.-person rule or its freeze and forced-transfer terms. Both tokens name that prospectus on chain. FILQ is USD Digital Liquidity Fund SP, a segregated portfolio of Fidelity International Strategies Funds SPC. That company is a Cayman Islands fund regulated by the Cayman Islands Monetary Authority and managed from Luxembourg. Fidelity International, its sponsor, is a separate company from the U.S. Fidelity group behind FDIT. FILQ takes orders at any hour. Fidelity International markets it “for professional investors only,” through appointed distributors, at US $100,000, so a US adviser cannot reach it on the published terms.

Review triggers
• Fidelity International publishes a readable prospectus, or states whether U.S. persons may hold and what freeze and forced-transfer powers it has
• Fidelity International opens a U.S. distribution channel
• The fund queues redemptions or deals at market NAV
• Either token’s implementation or permission manager changes

Ketju checks this memo every night and opens a review if its venues or files show a warning or a cited document changes. The first confirmation is due 2027-03-23.

Research

How it works

FILQ launched in May 2026 on Ethereum through Sygnum’s tokenization platform. Apex Group is transfer agent, and J.P. Morgan is custodian. There are two classes. FILQ-A adds its income to the token’s price. FILQ-D holds a constant price and pays dividends.

The holder owns a share of a segregated portfolio. By law, a Cayman segregated portfolio company keeps each portfolio’s assets and debts apart from the others. FILQ’s holders therefore have no claim on, and no exposure to, other portfolios of the same company. The fund is registered with CIMA under the Mutual Funds Act. FIL Investment Management (Luxembourg) manages it, and Moody’s rates it Aaa-mf. The transfer agent “maintains the official register of shareholders,” so the chain holds a copy of that register.

Fees

The fund charges 0.50 percent a year in total.

Withdrawals

FILQ takes orders in USDC, PYUSD, RLUSD or Fidelity’s own FIDD, which it swaps to dollars. A money market fund can pay out at once only if it holds cash or can borrow. FILQ defines market hours as 1:00 a.m. to 9:00 p.m. London time, Monday to Friday. Inside those hours it deals on confirmed funds and settles “near-immediate.” Outside them it pays redemptions from “available liquidity facilities (including cash buffers, credit facilities and repurchase arrangements) and not by portfolio liquidation.” It may charge 0.02 percent of NAV for each day the fund carries the cost.

When requests exceed those facilities, they wait in a queue until liquidity returns or markets reopen. Processing stops each Saturday from 3:00 to 6:00 p.m. Eastern for maintenance. The fund strikes its NAV at 9:00 p.m. London. In a stressed market, FILQ-D stops dealing at its constant price and uses market NAV, which may be lower. A holder can therefore redeem at the weekend, but only up to a limit that the fund does not publish.

Eligibility

Fidelity International sells to professional investors through an appointed distributor. The investor must pass know-your-customer and anti-money-laundering checks and wallet approval, and needs US $100,000 to open. The landing page says a UK distributor is “soon available.” It says nothing about U.S. persons. A secondary data site says the fund is not open to them. The prospectus would settle the question, but the server refused our requests for it. We therefore treat the fund as closed to U.S. persons.

Who controls it

Both classes are UUPS proxies over one Sygnum implementation, SygToken. We found a permission manager, a blacklist, a pause, a burn that can reach a holder’s balance, a role-gated mint and an upgrade function. The verified code also has forcedTransfer and recoverFunds. We did not determine who holds these roles. Fidelity International’s pages describe access control that the transfer agent runs, but they do not describe freezing or forced transfer.

Size and holdings

On 23 September 2026 FILQ-A had 252,517 tokens at $101.28, about $25.6 million, across three holders. FILQ-D had about $0.2 million across two holders.

Comparison

Sygnum’s FIUSD wraps a Fidelity International Irish fund in a Swiss bank’s claim; FILQ is the fund itself. Compared with FDIT, FILQ is offshore, sold to professionals and dealt around the clock. On the published terms, a U.S. household cannot reach either the fund or its tokens.

Sources

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

• Fidelity International: FILQ landing page (Wayback Machine copy, 19 September 2026) · primary · accessed 2026-09-23
  Supports: Cayman SPC, CIMA, Luxembourg manager, professional investors only, US $100,000, transfer agent register, stablecoin dealing, market hours, liquidity facilities, 2 bp per day fee, queue, stressed-market NAV, NAV at 9 p.m., TER 0.50%, Saturday maintenance
• Apex Group: transfer agency for FILQ · primary · accessed 2026-09-23
  Supports: Apex transfer agent
• Maples Group: advises on Fidelity International’s first tokenised liquidity fund · primary · accessed 2026-09-23
  Supports: Aaa-mf, CIMA registered, European AIFM
• Fidelity International Strategies Funds SPC prospectus (named by getTokenURI(); the server refused our requests) · primary · accessed 2026-09-23
  Supports: prospectus not readable
• Ledger Insights: Fidelity International issues tokenized MMF with Sygnum · secondary · accessed 2026-09-23
  Supports: May 2026 launch, Desygnate, separate from FIUSD
• Etherscan: FILQ-A token · secondary · accessed 2026-09-23
  Supports: supply, holders

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.