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Eligibility file · Mixed

Dinari dShares (tokenized US stocks and ETFs)

What the client owns
The holder has no title to the share, but has a claim to its value and a contractual put against Dinari. Third-party synthetic: A note or swap that pays like the security and carries no rights in it.
Who may hold it
Not offered to US persons. First purchase minimum not stated. The terms rely on Regulation S (Section 7.1(g)) and list the United States as an Excluded Jurisdiction. Distributors run KYC on their end users unless they engage Dinari (Section 2.4), and only holders who pass KYC may request a repurchase. Dinari offers a separate US brokerage route through Dinari Securities, LLC (CRD 329672), cleared by Alpaca. Its Form CRS says the customer may move the record token to a self-custody wallet they control (https://dinari.com/bd/crs). The partner guide still says issued US tokens are non-transferable, bars DeFi and wrapped dShares, and requires dedicated wallets tied to verified accounts (https://docs.dinari.com/docs/us). These documents conflict. The CRS does not grant transfers to other holders or state an allowlist. Part II of the customer agreement governs brokerage services, and service-specific supplemental terms control where the two conflict (https://dinari.com/bd/terms, Part I Section 1 and Part II Section 1). We did not verify any wallet-transfer supplement. This file covers the global Regulation S token. The developer guide links an external wallet to an account by a signed nonce (https://docs.dinari.com/docs/managing-wallets). The TokenTransfer API accepts a recipient account ID and lets only accounts with Dinari-managed wallets start a transfer (https://docs.dinari.com/reference/createtokentransfers). Neither document states a US recipient allowlist. For US fractional shares, the customer agreement bars in-kind transfers and requires a sale and then a wire of the proceeds (https://dinari.com/bd/terms, Section 20). A move of a record token under the CRS does not show that a holder can sell or transfer to another holder. We did not verify any US token redemption terms. At Arbitrum block 510472741, the sampled USFR token still points to implementation 0xf971cd2516eae8bb197ee21987a8421069bd0a68. For ordinary transfers, its source calls phase-2 rules at the access-control contract, and the operator role skips that check. The interface tracks registration, restriction, block and whitelist flags (https://sourcify.dev/server/v2/contract/42161/0xf971cd2516eae8bb197ee21987a8421069bd0a68?fields=all). In a read-only call, the contract allowed address 0x0000000000000000000000000000000000000001 to send to address 0x0000000000000000000000000000000000000002, and address 1 had no metadata flags (https://arb1.arbitrum.io/rpc). We found no verified source for the rule facet at Sourcify or Blockscout. We have not verified the US customer flags or the full recipient rules. Our read-only call does not prove that a US wallet can transfer, or that a holder has a legal right to transfer. We have not verified the allowlist, and our readings of the other chains date from September 24.
Who can freeze or claw back
Arbitrum USFR: can freeze a holder, pause transfers, claw back, mint, change the code (allowlist unverified). A single key, through a contract, can claw back tokens and pause transfers and freeze a holder. A single key can change the code with no delay.
Base USFR: can freeze a holder, pause transfers, claw back, mint, change the code (allowlist unverified). A single key, through a contract, can claw back tokens and pause transfers and freeze a holder. A single key can change the code with no delay.
Ethereum USFR: can freeze a holder, pause transfers, claw back, mint, change the code (allowlist unverified). A single key, through a contract, can claw back tokens and pause transfers and freeze a holder. A single key can change the code with no delay.
Plume Mainnet USFR: can freeze a holder, pause transfers, claw back, change the code (allowlist unverified). A single key, through a contract, can claw back tokens and pause transfers and freeze a holder. A single key can change the code with no delay.
How a holder redeems
Redeem with the issuer in its window. The holder places a sell order with Dinari. Dinari sells the underlying in the first available market session (regular or extended hours) and burns the tokens. It pays the sale price less third-party costs and posted fees, and may set size limits and defer settlement (Section 6.6). Settles in USDC, USDT.

In plain words on RIADeFi: Dinari dShares.

This file replaced an earlier version on 2026-09-30. The file called US dShares non-transferable. The Form CRS says a customer can move them to a wallet they control, while the partner guide still bars transfers. This revision records the conflict, the account terms for exits, and the limits of the on-chain checks. Earlier versions.

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The verdict is on the memo: Dinari dShares Not approved

Issuer
Dinari, Inc. (Delaware); underlying shares held for the token program in a Bermuda segregated accounts company; orders executed and cleared through Alpaca Securities LLC
Registration
Regulation S, offshore
Official record
No transfer agent
Instruments
USFR JAAA MSTR NVDA STRC NKE TSLA ASST
Chains
Arbitrum, Base, Ethereum, Plume Mainnet
Reviewed
2026-09-30
Next review
2027-03-23

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

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.

What the holder owns

The holder has no title to the share, but has a claim to its value and 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. dShares Terms and Conditions linked by Terms of Service (revised December 26, 2025) · 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. dShares Terms and Conditions linked by Terms of Service (revised December 26, 2025) · Section 7.1(g), page 11-12 · words found 2026-09-23

First purchase minimum

The documents we read do not state this.

Not stated in Dinari Inc. dShares Terms and Conditions linked by Terms of Service (revised December 26, 2025), Dinari 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. dShares Terms and Conditions linked by Terms of Service (revised December 26, 2025) · Preamble, page 1 · words found 2026-09-23

Who it may be transferred to

For the global token, Dinari says it refuses transfers to US persons, and the terms void nonconforming transfers. Dinari’s disclosures for its separate US brokerage route conflict. The CRS permits a move to a wallet the customer controls, but the US partner guide still bars transfers. Neither document states a US recipient allowlist; the eligibility notes give the detail.

“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 Restrictions · Regulatory section · words found 2026-09-23

How a holder redeems

On a sell order, Dinari sells the underlying at market, burns the tokens, and pays 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. dShares Terms and Conditions linked by Terms of Service (revised December 26, 2025) · 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. dShares Terms and Conditions linked by Terms of Service (revised December 26, 2025) · 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

FactAnswer
Who onboards the holderdistributor
Voting rightsNone
Distributionscash
SIPC coverage of the walletNo

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.

TokenChainFreeze a holderPauseClaw backGate holdersChange the codeKeys held by
USFRArbitrumYesYesYesUnverifiedYesA single key, through a contract, can claw back tokens and pause transfers and freeze a holder. A single key can change the code with no delay.
USFRBaseYesYesYesUnverifiedYesA single key, through a contract, can claw back tokens and pause transfers and freeze a holder. A single key can change the code with no delay.
USFREthereumYesYesYesUnverifiedYesA single key, through a contract, can claw back tokens and pause transfers and freeze a holder. A single key can change the code with no delay.
USFRPlume MainnetYesYesYesUnverifiedYesA single key, through a contract, can claw back tokens and pause transfers and freeze a holder. A single key can change the code with no delay.

Who holds the keys

Ketju read every current holder of each power from the chain on 2026-09-24. 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.

TokenChainKeyWhat it can doHeld byAddress
USFRArbitrumBeacon ownerchange the codea single key0x06b0…60a3
USFRArbitrumToken operator rolemint new tokens, claw back tokens, pause transfersa contract0xf60f…8766
USFRArbitrumToken operator rolemint new tokens, claw back tokens, pause transfersa contract run by a single key0xfa92…131d
USFRArbitrumToken operator rolemint new tokens, claw back tokens, pause transfersa contract run by a single key0x9108…9a8c
USFRArbitrumToken operator rolemint new tokens, claw back tokens, pause transfersa single key0x4008…bab5
USFRArbitrumToken operator rolemint new tokens, claw back tokens, pause transfersa single key0xc96f…9af6
USFRArbitrumToken operator rolemint new tokens, claw back tokens, pause transfersa single key0x7ec0…a876
USFRArbitrumRestrictor rolefreeze a holdera single key0x0111…204d
USFRBaseBeacon ownerchange the codea single key0x06b0…60a3
USFRBaseToken operator rolemint new tokens, claw back tokens, pause transfersa contract0xf60f…8766
USFRBaseToken operator rolemint new tokens, claw back tokens, pause transfersa contract run by a single key0x63ff…39c0
USFRBaseToken operator rolemint new tokens, claw back tokens, pause transfersa single key0x4008…bab5
USFRBaseToken operator rolemint new tokens, claw back tokens, pause transfersa single key0xc96f…9af6
USFRBaseToken operator rolemint new tokens, claw back tokens, pause transfersa single key0x7ec0…a876
USFRBaseRestrictor rolefreeze a holdera single key0x0111…204d
USFREthereumBeacon ownerchange the codea single key0x06b0…60a3
USFREthereumToken operator rolemint new tokens, claw back tokens, pause transfersa contract0xf60f…8766
USFREthereumToken operator rolemint new tokens, claw back tokens, pause transfersa contract run by a single key0xa8a4…79cb
USFREthereumToken operator rolemint new tokens, claw back tokens, pause transfersa contract run by a single key0xecab…9a9e
USFREthereumToken operator rolemint new tokens, claw back tokens, pause transfersa single key0x4008…bab5
USFREthereumToken operator rolemint new tokens, claw back tokens, pause transfersa single key0xc96f…9af6
USFREthereumToken operator rolemint new tokens, claw back tokens, pause transfersa single key0x7ec0…a876
USFREthereumRestrictor rolefreeze a holdera single key0x0111…204d
USFRPlume MainnetBeacon ownerchange the codea single key0x06b0…60a3
USFRPlume MainnetToken operator rolemint new tokens, claw back tokens, pause transfersa contract0xf60f…8766
USFRPlume MainnetToken operator rolemint new tokens, claw back tokens, pause transfersa contract run by a single key0xc157…6bab
USFRPlume MainnetToken operator rolemint new tokens, claw back tokens, pause transfersa single key0x4008…bab5
USFRPlume MainnetToken operator rolemint new tokens, claw back tokens, pause transfersa single key0xc96f…9af6
USFRPlume MainnetToken operator rolemint new tokens, claw back tokens, pause transfersa single key0x7ec0…a876
USFRPlume MainnetRestrictor rolefreeze a holdera single key0x0111…204d
Arbitrum USFR: 9 contract reads, 4 functions in verified source, 2026-09-30
Read from the chain
  • beacon.implementation()=0xf971cd2516eae8bb197ee21987a8421069bd0a68
  • accessControl()=0xf60f689ec22fc2d485b3c734efe58538ccc28766
  • TransferRestrictor_getUserAddressMetadata(0x0000000000000000000000000000000000000001)=(false,false,false,false,0x0000000000000000000000000000000000000000)
  • facetAddress(0x83609b0f)=0xabd5fc79dc9f43e5ba94869c396a80f27d6c7efa
  • isTransferAllowed(0x0000000000000000000000000000000000000001,0x0000000000000000000000000000000000000002)=true
  • eip1967.beacon=0x15436013850211acf89b656f34b426fdae01dacb
  • 0x15436013850211acf89b656f34b426fdae01dacb.implementation()=0xf971cd2516eae8bb197ee21987a8421069bd0a68
  • paused()=false
  • accessControl()=0xf60f689ec22fc2d485b3c734efe58538ccc28766
Read from verified source
Base USFR: 4 contract reads, 4 functions in verified source, 2026-09-24
Read from the chain
  • eip1967.beacon=0x6aa1bda7e764bc62589e64f371a4022b80b3c72a
  • 0x6aa1bda7e764bc62589e64f371a4022b80b3c72a.implementation()=0x6658e71ab4653d398bfd12e9bf70e9a2e40de28c
  • paused()=false
  • accessControl()=0xf60f689ec22fc2d485b3c734efe58538ccc28766
Read from verified source
Ethereum USFR: 4 contract reads, 4 functions in verified source, 2026-09-24
Read from the chain
  • eip1967.beacon=0x4062d9cbf85da2913880a3a5641cf05e85774f27
  • 0x4062d9cbf85da2913880a3a5641cf05e85774f27.implementation()=0x8b2592dfb8b375cc67e448d5694b1f8b33ecc624
  • paused()=false
  • accessControl()=0xf60f689ec22fc2d485b3c734efe58538ccc28766
Read from verified source
Plume Mainnet USFR: 4 contract reads, 4 functions in verified source, 2026-09-24
Read from the chain
  • eip1967.beacon=0xf4950a31566cdba1140058178e1aa3ec8aff3228
  • 0xf4950a31566cdba1140058178e1aa3ec8aff3228.implementation()=0xbc678305546102ac32932d46eb8b4be62a168c0d
  • paused()=false
  • accessControl()=0xf60f689ec22fc2d485b3c734efe58538ccc28766
Read from verified source

Where it trades

VenueKind
Dinari API and partner appsissuer primary
Hyperliquid HyperCore spot (wrapped dShares)dex

Redemption

RouteSettlementSettles in
Redeem with the issuer in its windowThe holder places a sell order with Dinari. Dinari sells the underlying in the first available market session (regular or extended hours) and burns the tokens. It pays the sale price less third-party costs and posted fees, and may set size limits and defer settlement (Section 6.6)USDC, USDT

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. 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.

DateChange
2026-09-23Filed.
2026-09-24Revised. Superseded to correct the allowlist and settle the Plume clawback. The Plume clawback, marked unverified, is read from verified source: the contract can take a holder’s tokens. The allowlist the file recorded as true on Ethereum, Arbitrum, Base, and Plume rested on function names: every transfer asks Dinari’s access-control contract, whose source is not published anywhere readable, so the allowlist is unverified on all four chains.
2026-09-30Revised. The file called US dShares non-transferable. The Form CRS says a customer can move them to a wallet they control, while the partner guide still bars transfers. This revision records the conflict, the account terms for exits, and the limits of the on-chain checks.

Sources

Every file is public. With a subscription, Ketju checks each of your households against the file and checks the file every day. $299 per firm per month, first 30 days free. Start the trial.