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Eligibility file · Money-market fund

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

What the client owns
Accumulating share of USD Digital Liquidity Fund SP, a Cayman money market fund; income compounds into the token’s NAV; Distributing share of USD Digital Liquidity Fund SP at a constant NAV, paying daily or monthly dividends. Issuer indirect: The token points at a record kept off chain; the transfer agent’s file governs and the chain is a mirror.
Who may hold it
Not offered to US persons. First purchase $100,000. Fidelity International markets the fund to professional investors only, through appointed distributors, with KYC and AML checks and a whitelisted wallet. The first investment is US $100,000. The landing page says nothing about U.S. persons, and we could not read the prospectus because its site blocks automated reads. A secondary data site says the fund is not available to U.S. persons. We apply the stricter reading: non-U.S. persons only.
Who can freeze or claw back
Ethereum FILQ-A: can freeze a holder, pause transfers, claw back, gate who may hold, mint, change the code.
Ethereum FILQ-D: can freeze a holder, pause transfers, claw back, gate who may hold, mint, change the code.
How a holder redeems
Redeem with the issuer in its window. Orders are taken 24/7 through the transfer agent or a distributor. Stablecoins are exchanged into dollars before investment and back on redemption. In market hours (1:00 a.m. to 9:00 p.m. London, Monday to Friday), settlement is near-immediate on confirmed funds. Outside them, redemptions draw on cash buffers, credit lines, and repo; they may cost 2 basis points a day and may be queued when those run short. In a stressed market, deals move from constant NAV to market NAV. Settles in USD, USDC, PYUSD, RLUSD, FIDD.

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The verdict is on the memo: Fidelity International USD Digital Liquidity Fund (FILQ-A, FILQ-D) Under review

Issuer
Fidelity International Strategies Funds SPC, for its segregated portfolio USD Digital Liquidity Fund SP, a Cayman Islands mutual fund regulated by CIMA; FIL Investment Management (Luxembourg) S.à r.l. as manager; Apex Group as transfer agent; J.P. Morgan as custodian and administrator; Sygnum (Desygnate) as tokenization platform
Registration
Other
Official record
Apex Group (Apex Fund Services)
Instruments
FILQ-A FILQ-D
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.

What the holder owns

A share of USD Digital Liquidity Fund SP, a segregated portfolio of a Cayman Islands SPC.

“Fidelity International Strategies Funds SPC – USD Digital Liquidity Fund SP (FILQ) keeps cash working”

Fidelity International: FILQ landing page (Wayback Machine copy, 19 September 2026) · What is FILQ? · words found 2026-09-23

Who may hold it

Professional investors only.

“Marketing Communication. Capital at risk. For professional investors only.”

Fidelity International: FILQ landing page (Wayback Machine copy, 19 September 2026) · Page header · words found 2026-09-23

Who may hold it

Through an appointed distributor, after KYC and AML checks and wallet approval.

“Investors will be subject to standard checks, including KYC and AML, and their digital asset wallets must be approved and whitelisted before transacting, where access is available.”

Fidelity International: FILQ landing page (Wayback Machine copy, 19 September 2026) · FAQ, How can investors access FILQ? · words found 2026-09-23

First purchase minimum

US $100,000 first investment.

“The minimum initial investment in FILQ is US $100,000.”

Fidelity International: FILQ landing page (Wayback Machine copy, 19 September 2026) · FAQ, What is the minimum investment size? · words found 2026-09-23

Who it may be transferred to

Only approved, whitelisted wallets may subscribe, hold, or redeem.

“FILQ operates a permissioned token model. Only approved and whitelisted investor wallets may subscribe for, hold, or redeem fund tokens.”

Fidelity International: FILQ landing page (Wayback Machine copy, 19 September 2026) · FAQ, What token standard is used · words found 2026-09-23

How a holder redeems

Outside London market hours, redemptions draw on liquidity facilities, not asset sales, and may be queued.

“Outside Market Hours, redemption requests are supported by available liquidity facilities (including cash buffers, credit facilities and repurchase arrangements) and not by portfolio liquidation.”

Fidelity International: FILQ landing page (Wayback Machine copy, 19 September 2026) · 24/7 Dealing and Liquidity Framework · words found 2026-09-23

How a holder redeems

Redemptions settled outside market hours may cost 2 basis points of NAV a day.

“Redemptions settled Outside Market Hours may be subject to a redemption fee of 0.02% of Net Asset Value per day (2 basis points per day).”

Fidelity International: FILQ landing page (Wayback Machine copy, 19 September 2026) · 24/7 Dealing and Liquidity Framework · words found 2026-09-23

Who keeps the official record

The transfer agent keeps the official register of shareholders and runs access control.

“Access control is administered by the fund’s transfer agent, with onboarding supported by appointed distributors. The transfer agent maintains the official register of shareholders and retains oversight of access and controls.”

Fidelity International: FILQ landing page (Wayback Machine copy, 19 September 2026) · FAQ, What token standard is used · words found 2026-09-23

What the issuer says it can freeze or take back

The published pages do not describe freeze or forced-transfer powers, and we could not read the prospectus because its site blocks automated reads. On chain, the token contract has functions to blacklist, pause, burn, and force a transfer.

Not stated in Fidelity International: FILQ landing page (Wayback Machine copy, 19 September 2026), Apex Group: transfer agency for Fidelity International’s first tokenised product, Maples Group: advises on Fidelity International’s first tokenised liquidity fund, Fidelity International: Fidelity International Strategies Funds SPC prospectus, named by both tokens’ getTokenURI() (its site blocks automated reads).

FactAnswer
Who onboards the holderdistributor
Voting rightsNone
Distributionsreinvested
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
FILQ-AEthereumYesYesYesYesYesrole-gated mint
FILQ-DEthereumYesYesYesYesYesrole-gated mint
Ethereum FILQ-A: 2 contract reads, 6 functions in verified source, 2026-09-23
Read from the chain
  • eip1967.implementation=0x7030fe438be6ed196b8886616bbf5a245c267339
  • isPaused()=false
Read from verified source
Ethereum FILQ-D: 2 contract reads, 6 functions in verified source, 2026-09-23
Read from the chain
  • eip1967.implementation=0x7030fe438be6ed196b8886616bbf5a245c267339
  • isPaused()=false
Read from verified source

Where it trades

VenueKind
Fidelity International appointed distributors and Apex Groupissuer primary

Redemption

RouteSettlementSettles in
Redeem with the issuer in its windowOrders are taken 24/7 through the transfer agent or a distributor. Stablecoins are exchanged into dollars before investment and back on redemption. In market hours (1:00 a.m. to 9:00 p.m. London, Monday to Friday), settlement is near-immediate on confirmed funds. Outside them, redemptions draw on cash buffers, credit lines, and repo; they may cost 2 basis points a day and may be queued when those run short. In a stressed market, deals move from constant NAV to market NAV.USD, USDC, PYUSD, RLUSD, FIDD

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 not revised this file since filing it. If Ketju revises it, the earlier version stays as published, with the reason.

DateChange
2026-09-23Filed.

Sources

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