Dinari dShares (tokenized US stocks and ETFs)

Research and shelf status are on the memo: Dinari dShares Adverse research finding

Other programs tokenize the same securities. Every version side by side: USFR, JAAA, MSTR, NVDA, STRC, NKE, TSLA, ASST.

Who may buy, hold, transfer, and redeem

Each answer rests on the issuer’s own words, quoted from the document named under it. Ketju re-reads each document and records whether the words are still there. Where the documents say nothing, the row says so.

What the holder owns

No title to the share: a claim to its value plus a contractual put against Dinari.

“While you will not have any claim of right or title to the actual Underlying Asset, you do have a claim to the value of said underlying asset, at the market value that is set out on the Dinari Website when you sell the Token.”

Dinari, Inc. Terms and Conditions for dShares (revised 12.26.25) · Section 4.6(a), page 8; see also Section 6.8 · words found 2026-09-23

Who may hold it

Non-US persons only. The terms rely on Regulation S and list the United States as an excluded jurisdiction.

“You certify that you, and any other holder of Tokens due to a Distribution by you, are not a “U.S. Person,” (a “Non-U.S. Person”) as defined under Regulation S and is not acquiring the Tokens for the account or benefit of any U.S. Person.”

Dinari, Inc. Terms and Conditions for dShares (revised 12.26.25) · Section 7.1(g), page 11-12 · words found 2026-09-23

First purchase minimum

The documents read do not say.

Not stated in Dinari, Inc. Terms and Conditions for dShares (revised 12.26.25), Dinari docs: Restrictions, Dinari sbt-contracts: TransferRestrictor.sol (issuer-published source).

Account types

Individuals and companies buy directly; distributors and aggregators may buy and hold for their own end users under added terms.

“If you are making any purchase as an Aggregator, with a view to compliantly hold Tokens on behalf of one or more third party individuals, while conferring certain contractual rights upon those individuals, you also must comply with the Additional Terms for Aggregators set out at Annex 4.”

Dinari, Inc. Terms and Conditions for dShares (revised 12.26.25) · Preamble, page 1 · words found 2026-09-23

Who it may be transferred to

Transfers to US persons are barred; Dinari says it will refuse to effect or register them, and nonconforming transfers are void.

“Dinari will not effect or register any transfer of the Product made in violation of Regulation S and, more specifically, will refuse to effect or transfer any Product made to any U.S. person.”

Dinari docs: Restrictions · Regulatory section · words found 2026-09-23

How a holder redeems

A sell order makes Dinari sell the underlying at market, burn the tokens, and pay the proceeds less costs in a dollar stablecoin.

“At or near the time the Sell Order is complete, Dinari will burn the Repurchase Tokens and will pay the aggregate Repurchase Price in USD-denominated stablecoin or other acceptable digital asset to the Participant’s Digital Wallet that is connected to the Participant’s Account.”

Dinari, Inc. Terms and Conditions for dShares (revised 12.26.25) · Section 6.4, page 10 · words found 2026-09-23

Who keeps the official record

Dinari is the holder of record of the underlying shares and keeps the vote.

“Aggregators or Distributors may disclose to their Users that Tokens confer no voting rights and that Dinari is the holder of record.”

Dinari, Inc. Terms and Conditions for dShares (revised 12.26.25) · Section 4.6(d), page 8 · words found 2026-09-23

What the issuer says it can freeze or take back

A Dinari compliance role can blacklist any address; a blacklisted address cannot send or receive dShares.

“/// @notice Accounts in `isBlacklisted` cannot send or receive tokens”

Dinari sbt-contracts: TransferRestrictor.sol (issuer-published source) · TransferRestrictor.sol, state variable isBlacklisted (repo main, last push 2026-02-06) · the site refuses automated reads; quoted as read 2026-09-23

Who can change the record

Powers read from the deployed contracts and their verified source: the token and every contract it consults on transfer. A power recorded here is the issuer’s ability, not evidence it has been used.

Who holds the keys

Every current holder of each power, read from the chain on 2026-09-23. A single key is one private key: whoever holds it acts alone. A multisig needs the stated number of signers. A timelock makes every action wait, so holders can see it coming.

Where it trades

How it exits

Reopen conditions: events that change an answer above
• Dinari revises its dShares Terms and Conditions, in particular Sections 4.6, 6 or 6.8 on title, the repurchase right, or holder of record
• Dinari opens transferable dShares to US persons, or Dinari Securities lets US tokens move off its dedicated wallets
• The TransferRestrictor blacklist is used against a holder, or the restrictor, beacon implementation, or MINTER/BURNER roles change on any chain
• Dinari adds or deprecates a chain, or moves tokens between chains as it did from Blast to Arbitrum on April 20, 2026
• The Bermuda segregated accounts company, its representative, or the custodian or clearing broker (Alpaca Securities) changes
• A dShare trades more than 2% from its underlying for a full session, or a repurchase is deferred under Section 6.6
• SEC or FINRA action on synthetic tokenized securities, Dinari, Inc., or Dinari Securities, LLC

What the monitor reads daily

Every control function in the table above and the contracts the token consults on transfer; the token’s on-chain supply against yesterday’s; and its market quote against yesterday’s quote. Every document quoted above is re-read too, and a quote that leaves its document reopens the file. A change opens a review item in the governance queue and reopens the file before any client action.

Sources

• Dinari, Inc. Terms and Conditions for dShares (revised 12.26.25) · primary · accessed 2026-09-23
  Supports: Regulation S; US persons excluded, claim to value, no title, contractual put, not ownership, Dinari holder of record, keeps vote, Bermuda segregated accounts company, repurchase mechanics and settlement, dividends in stablecoin, under $1 not paid, Annex 5 wind-down by segregated account representative
• Dinari docs: Restrictions · primary · accessed 2026-09-23
  Supports: refuses transfers to US persons, unsupported countries
• Dinari sbt-contracts: TransferRestrictor.sol (issuer-published source) · primary · accessed 2026-09-23
  Supports: blacklist blocks send and receive, RESTRICTOR_ROLE
• Dinari sbt-contracts: DShare.sol (issuer-published source) · primary · accessed 2026-09-23
  Supports: MINTER_ROLE and BURNER_ROLE, burnFrom requires allowance in published source, transfer restrictor hook
• Dinari sbt-contracts: DShareFactory release deployments · primary · accessed 2026-09-23
  Supports: factory addresses per chain, instrument anchors
• Dinari docs: Blockchain (supported chains) · primary · accessed 2026-09-23
  Supports: Ethereum, Arbitrum, Avalanche, Base, HyperEVM, HyperCore, Plume, Blast and Kinto deprecated
• Dinari docs: Deprecation Notices · primary · accessed 2026-09-23
  Supports: Blast support ended April 20, 2026; tokens moved to Arbitrum, Kinto shutdown September 30, 2025
• Dinari docs: What are dShares · primary · accessed 2026-09-23
  Supports: mint and burn only on filled brokerage order, Alpaca executes the hedge
• Dinari docs: Partner Fees · primary · accessed 2026-09-23
  Supports: $0.20 standard network fee per order, OTC minimum $25,000 for partners, API access from $2,000 per month
• Dinari docs: Dividends · primary · accessed 2026-09-23
  Supports: dividends paid in USD+, $0.10 minimum per holder
• Dinari docs: US Customers · primary · accessed 2026-09-23
  Supports: US tokens non-transferable and barred from DeFi, Dinari Securities onboarding and KYC, Alpaca clearing, USDC funding via Circle
• Dinari Securities, LLC Form CRS (effective August 31, 2026) · primary · accessed 2026-09-23
  Supports: secondary record keeping token, no minimum account size, proprietary products only, Alpaca clearing firm
• Dinari Securities, LLC Website Terms of Use and Customer Brokerage Agreement (July 29, 2026) · primary · accessed 2026-09-23
  Supports: US residents only, sole owner, personal non-business use, records kept through clearing agency
• Dinari Securities, LLC Form X-17A-5 for period ending December 31, 2025 · primary · accessed 2026-09-23
  Supports: SEC registration June 20, 2025, no customer accounts at December 31, 2025, total assets $251,516, Alpaca clearing deposit $30,000
• FINRA BrokerCheck: Dinari Securities, LLC (CRD 329672) · primary · accessed 2026-09-23
  Supports: approved 06/20/2025, 53 state registrations, no disclosures
• SEC EDGAR: Dinari, Inc/TA (Form TA-1 and TA-2 filings) · primary · accessed 2026-09-23
  Supports: Dinari, Inc. registered transfer agent since 2022
• dinari.com home page (Global and US versions) · primary · accessed 2026-09-23
  Supports: marketing says dShares are stocks, available in the US and 85+ jurisdictions
• Dinari price feed (CoinGecko tickers endpoint) · primary · accessed 2026-09-23
  Supports: prices used to rank dShares by value
• SEC Divisions of Corporation Finance, Investment Management, and Trading and Markets: Statement on Tokenized Securities, January 28, 2026 · primary · accessed 2026-09-23
  Supports: synthetic tokenized security: linked security, custodial model requires ownership interest