Eligibility file · Credit fund

Janus Henderson Anemoy AAA CLO Fund (JAAA)

What the client owns

Share of a British Virgin Islands open-ended professional fund holding AAA-rated CLO tranches. Issuer direct: The on-chain record is the securityholder file; the holder is the registered owner.

Who may hold it

Not offered to US persons. First purchase $500,000. The fact sheet states the minimum as 500,000 USDC.

Who can freeze or claw back

Ethereum: can freeze a holder, claw back, gate who may hold, mint, change the code. A contract can claw back tokens and freeze a holder. A contract can change the code with no delay.

How a holder redeems

Redeem with the issuer in its window. Daily subscriptions and redemptions in stablecoins through Centrifuge at the published NAV. Settles in USDC, other stablecoins.

This file replaced an earlier version on 2026-09-23. Superseded the same day: the control reading stopped at the token ABI and missed the Centrifuge FullRestrictions hook every transfer calls, which can freeze a holder, and the file() setter that can replace it. The file said no freeze and not upgradeable. Same claim model, terms, and exit. Earlier versions.

Subscribers see which of their clients hold this program and whether each household qualifies under these terms, and Ketju emails them when the file changes. $299 per firm per month, first 30 days free.

The verdict is on the memo: Centrifuge (JAAA) Not approved

Issuer

Anemoy Capital SPC Limited (BVI professional fund); Janus Henderson as sub-investment manager

Registration

Regulation S, offshore

Official record

Anemoy Capital SPC Limited (share register kept on Centrifuge)

Instruments

JAAA

Chains

Ethereum

Reviewed

2026-09-23

Next review

2027-03-23

Eligibility

Each answer quotes the issuer’s own words from the document named under it. Ketju reads each document again and records whether the words are still there. Where the documents say nothing, the row states that.

Who may hold it

Non-US professional investors.

“Open ended BVI licensed fund for non-US Professional Investors”

Anemoy Capital SPC Limited, JAAA fact sheet, June 2026 (executive summary linked from pool metadata) · Overview · words found 2026-09-23

First purchase minimum

500,000 USDC.

“Min. investment 500,000 USDC”

Anemoy Capital SPC Limited, JAAA fact sheet, June 2026 (executive summary linked from pool metadata) · Key Facts table · words found 2026-09-23

Account types

The documents we read do not state this.

Not stated in Anemoy Capital SPC Limited, JAAA fact sheet, June 2026 (executive summary linked from pool metadata), Anemoy: JAAA fund page, JAAA April 2026 factsheet, ipfs.centrifuge.io.

Who it may be transferred to

The documents we read do not state this.

Not stated in Anemoy Capital SPC Limited, JAAA fact sheet, June 2026 (executive summary linked from pool metadata), Anemoy: JAAA fund page, JAAA April 2026 factsheet.

How a holder redeems

Holders subscribe and redeem in USDC and other stablecoins.

“Subscription & redemption in USDC and other stablecoins”

Anemoy Capital SPC Limited, JAAA fact sheet, June 2026 (executive summary linked from pool metadata) · Overview · words found 2026-09-23

Who keeps the official record

The fund issues its shares as the JAAA token.

“The fund issues its shares as the JAAA token to investors.”

Anemoy Capital SPC Limited, JAAA fact sheet, June 2026 (executive summary linked from pool metadata) · Fund description · words found 2026-09-23

What the issuer says it can freeze or take back

Centrifuge, the tokenization platform, states that frozen addresses cannot send or receive tokens; Anemoy’s own documents do not say this.

“Account freezing - frozen addresses cannot send or receive tokens”

Centrifuge Docs, Token compliance (full-text export of docs.centrifuge.io); Centrifuge is the tokenization platform, not the fund issuer · Token compliance, Architecture · words found 2026-09-23

Fact	Answer
Who onboards the holder	issuer
Voting rights	None
Distributions	reinvested
SIPC coverage of the wallet	No

Who controls it

Ketju read these powers from the deployed contracts and their verified source code: the token and every contract it checks on a transfer. A power listed here is something the issuer can do; it does not mean the issuer has used it.

Chain	Freeze a holder	Pause	Claw back	Gate holders	Change the code	Keys held by
Ethereum	Yes	No	Yes	Yes	Yes	A contract can claw back tokens and freeze a holder. A contract can change the code with no delay.

Who holds the keys

Ketju read every current holder of each power from the chain on 2026-09-23. A single key is one private key, and whoever holds it acts alone. A multisig needs the stated number of signers. A timelock delays every action, so holders can see it before it takes effect.

Chain	Key	What it can do	Held by	Address
Ethereum	Ward	grant and revoke these powers, claw back tokens, mint new tokens, change the code, decide who may hold	a timelock with a 2-day delay	0x7ed4…368f
Ethereum	Ward	grant and revoke these powers, claw back tokens, mint new tokens, change the code, decide who may hold	a contract	0xec35…25ab
Ethereum	Ward	grant and revoke these powers, claw back tokens, mint new tokens, change the code, decide who may hold	a contract	0x12a1…f43e
Ethereum	Hook ward	grant and revoke these powers, freeze a holder, claw back tokens	a timelock with a 2-day delay	0x7ed4…368f
Ethereum	Hook ward	grant and revoke these powers, freeze a holder, claw back tokens	a contract	0xec35…25ab

Ethereum: 1 contract read, 5 functions in verified source, 2026-09-23

Read from the chain

hook()=0x3c5e7b28c4ff6f0bc8d9a9587992e96401e680a7

Read from verified source

checkTransferRestriction in verified source 0x5a0f…cf64
freeze in verified source 0x3c5e…80a7
authTransferFrom in verified source 0x5a0f…cf64
mint in verified source 0x5a0f…cf64
file in verified source 0x5a0f…cf64

Where it trades

Venue	Kind
Centrifuge (Anemoy pool)	issuer primary

Redemption

Route	Settlement	Settles in
Redeem with the issuer in its window	Daily subscriptions and redemptions in stablecoins through Centrifuge at the published NAV	USDC, other stablecoins

Review triggers

Anemoy publishes a minimum subscription or opens a share class to U.S. persons
The FullRestrictions hook is replaced through file(), a freeze is used against a holder, or a pause power is added to the token
A NAV-per-share move above 2% without explanation, a redemption gate, or a portfolio security below AAA
Centrifuge publishes JAAA on Base, Avalanche, BNB Chain, Arbitrum, Solana, Monad, and Pharos; Ketju reads only the Ethereum contract until it adds those contracts

Daily checks

Every day Ketju reads each control function in the table above and the contracts the token checks on a transfer. Ketju compares the token’s on-chain supply with yesterday’s, and its market quote with yesterday’s quote, since a fund of this kind accrues a few basis points a day. Ketju also reads every document quoted above and reviews the file again if a quoted passage disappears from its document. Ketju counts a new, removed, or changed key as a change only when the chain’s own log shows the grant, revocation, or signer change since yesterday. If the log does not show it, Ketju updates the key list in this file and does nothing more. A change opens a review before any client action. Subscribers get an email that names each of their clients who hold the token, with the household result.

File history

Ketju has revised this file 2 times since filing it. Ketju keeps each earlier version as published, with the reason for the change.

Date	Change
2026-09-23	Filed.
2026-09-23	Revised. Superseded the same day: the control reading stopped at the token ABI and missed the Centrifuge FullRestrictions hook every transfer calls, which can freeze a holder, and the file() setter that can replace it. The file said no freeze and not upgradeable. Same claim model, terms, and exit.
2026-09-23	Revised. Superseded to quote the issuer’s terms: the June 2026 fact sheet states a 500,000 USDC minimum and settlement in other stablecoins as well as USDC.

Sources

Anemoy: JAAA fund page · primary · accessed 2026-09-23
Supports: regulated open-ended BVI fund for non-US professional investors, subscriptions and redemptions in stablecoins, daily access and settlement
JAAA April 2026 factsheet · primary · accessed 2026-07-31
Supports: open to non-U.S. professional investors, AAA CLO portfolio
Centrifuge JAAA fund page · primary · accessed 2026-07-31
Supports: pool identity, NAV and holdings
Verified implementation on Ethereum (Sourcify) · primary · accessed 2026-09-23
Supports: ERC-1404 transfer restriction check, burn from a holder address, role-gated mint, no proxy
Anemoy Capital SPC Limited, JAAA fact sheet, June 2026 (executive summary linked from pool metadata) · primary · accessed 2026-09-23
Supports: who may-hold, minimum, redemption, record
Centrifuge Docs, Token compliance (full-text export of docs.centrifuge.io); Centrifuge is the tokenization platform, not the fund issuer · primary · accessed 2026-09-23
Supports: freeze
ipfs.centrifuge.io · primary · accessed 2026-09-23
Supports: checked for account types

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