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Eligibility file · Note

Ondo Global Markets (tokenized stocks and ETFs, ”on” tickers)

What the client owns
A structured note: a debt of Ondo Global Markets (BVI) Limited, a BVI special purpose company. Not the share itself. 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 $1. Direct mint and redeem need Ondo onboarding (Persona KYC, signed Sales Terms, allowlisted wallet), open to institutions only today. EEA retail may buy under the FMA base prospectus; UK, Switzerland, Singapore, Hong Kong, Malaysia, Brazil need professional or qualified status. Secondary holders need no KYC to hold but must pass it to redeem.
Who can freeze or claw back
Ethereum SPYon: can pause transfers, claw back, gate who may hold, mint, change the code. Compliance owner key: a 4-of-7 multisig. Code changes wait behind a timelock with a 2-hour delay.
BSC SPYon: can pause transfers, claw back, gate who may hold, mint, change the code (freeze unverified). Compliance owner key: a 4-of-7 multisig. Code changes wait behind a timelock with a 2-hour delay.
Solana SPYon: can freeze a holder, pause transfers, mint. An account only a program can sign for can freeze a holder and pause transfers. An account only a program can sign for can change the code with no delay.
How it exits
Redeem with the issuer in its window. Instant atomic mint or redeem against an Ondo-signed quote through GMTokenManager during 24/5 sessions; select assets also in an Off-Hours session. Settles in USDon, USDC, USDT.

Research and shelf status are on the memo: Ondo Global Markets (Ondo Stocks) Adverse research finding

Issuer
Ondo Global Markets (BVI) Limited (BVI company 2174192; 90.01% Flux Finance Inc., 9.99% Ondo Finance Inc.); Ondo Finance Inc. as tokenizer; Ankura Trust Company as security and verification agent
Registration
Regulation S, offshore
Official record
No transfer agent
Instruments
CRCLon IVVon SPYon MUon NVDAon QQQon MSTRon HIMSon
Chains
Ethereum, BSC, Solana, Hyperliquid L1
Reviewed
2026-09-23 · v1
Next review
2027-03-23

Other programs tokenize the same securities. Every version side by side: CRCL, IVV, SPY, MU, NVDA, QQQ, MSTR, HIMS.

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

A structured note: a debt of Ondo Global Markets (BVI) Limited, a BVI special purpose company. Not the share itself.

“An Ondo tokenized stock is a structured note: a debt instrument issued by Ondo Global Markets (BVI) Limited (known as the ”Issuer”), a bankruptcy-remote special purpose vehicle (SPV) organized in the British Virgin Islands (BVI).”

Ondo Stocks docs: Legal & Regulatory · How are Ondo tokenized stocks structured legally? · words found 2026-09-23

Who may hold it

US persons, and anyone placing an order from the US, may not subscribe, acquire, or redeem.

“Persons who place buy orders from within the United States, or any of its states, possessions, territories or federal districts, and persons who are ”U.S. persons” or acting for the account or benefit of any ”U.S. persons” within the meaning of Rule 902 of Regulation S promulgated under the United States Securities Act of 1933, as amended, are also prohibited from subscribing for, acquiring or redeeming Ondo Stocks.”

Ondo Stocks docs: Eligibility · Jurisdiction-Based Prohibitions, footnote · words found 2026-09-23

First purchase minimum

One dollar to invest or redeem directly.

“The minimum is just $1.00 USD.”

Ondo Stocks docs: Investing & Redeeming · What is the minimum I can invest or redeem? · words found 2026-09-23

Who it may be transferred to

Tokens move freely on chain outside the US, including to wallets that never passed Ondo KYC.

“All Ondo stocks are transferable outside the US across supported blockchains”

Ondo Stocks docs: Transferability · Are Ondo stock tokens transferable? · words found 2026-09-23

How a holder redeems

Redeem instantly to USDon; to USDC only while the swap contract holds enough USDC.

“The redemption to USDon will always be instant; redemptions to USDC will be instant provided there is enough liquidity in the stablecoin swapper.”

Ondo Stocks docs: Investing & Redeeming · Redeeming: What about redemptions? · words found 2026-09-23

Who keeps the official record

The token contract is the securities ledger for each note, under Swiss law.

“The address of the smart contract serving as the Securities Ledger of the Token is: 0x0e397938c1aa0680954093495b70a9f5e2249aba.”

Ondo Global Markets (BVI) Limited, Final Terms for Product Nr. 1 QQQon (ISIN VGG7001AAJ30), dated 11.11.2025, as filed with the MFSA · Part A, Address of smart contract serving as Securities Ledger (QQQon) · words found 2026-09-23

What the issuer says it can freeze or take back

Ondo’s Solana code notes list a global transfer pause. No Ondo document states a freeze or forced-burn power over holders.

“Pausable - Global transfer pause capability”

Ondo Global Markets Solana program README (ondoprotocol GitHub) · README, Token Extensions · words found 2026-09-23

FactWhat the file records
Who onboards the holderissuer
Voting rightsNone
Distributionsreinvested
SIPC coverage of the walletNo

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.

TokenChainFreeze a holderPauseClaw backGate holdersChange the codeKeys held by
SPYonEthereumNoYesYesYesYesCompliance owner key: a 4-of-7 multisig. Code changes wait behind a timelock with a 2-hour delay.
SPYonBSCUnverifiedYesYesYesYesCompliance owner key: a 4-of-7 multisig. Code changes wait behind a timelock with a 2-hour delay.
SPYonSolanaYesYesNoNoNoAn account only a program can sign for can freeze a holder and pause transfers. An account only a program can sign for can change the code with no delay.

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.

TokenChainKeyWhat it can doHeld byAddress
SPYonEthereumBeacon ownerchange the codea timelock with a 2-hour delay0x3715…34f1
SPYonEthereumCompliance ownerdecide who may hold, grant and revoke these powersa 4-of-7 multisig0x71a4…1646
SPYonEthereumMinter rolemint new tokensa contract0x2c15…5c8c
SPYonEthereumAdmin rolegrant and revoke these powersa timelock with a 2-hour delay0x3715…34f1
SPYonEthereumMinter rolemint new tokensa contract run by a contract0x61a6…bbf3
SPYonEthereumMinter rolemint new tokensa contract0xec8b…1f4e
SPYonBSCBeacon ownerchange the codea timelock with a 2-hour delay0x8860…3b26
SPYonBSCCompliance ownergrant and revoke these powersa 4-of-7 multisig0xa307…a913
SPYonSolanaMint authoritymint new tokensan account only a program can sign for9foMHs…cUxD
SPYonSolanaFreeze authorityfreeze a holderan account only a program can sign for51QVCu…hiuK
SPYonSolanaPause authoritypause transfersan account only a program can sign for9foMHs…cUxD
SPYonSolanaTransfer-hook authoritydecide who may hold, change the codean account only a program can sign for9foMHs…cUxD

Role holders on BSC could not be read from the public event indexes on the last reading; the table shows only what was confirmed.

Ethereum SPYon: 1 contract read at block 26037569, 4 functions in verified source, 2026-09-23
Read from the chain
  • compliance()=0x54a8757c2fef8649830b158a8c19d3a670e80318
Read from verified source
BSC SPYon: 1 contract read at block 123495019, 4 functions in verified source, 2026-09-23
Read from the chain
  • compliance()=0x76be569c94c39a2e2492de2f4d1c253f348250d0
Read from verified source
Solana SPYon: 3 contract reads at block 449584634, 0 functions in verified source, 2026-09-23
Read from the chain
  • mintAuthority=9foMHsSDq7nMg4WPusSz9eY7tyxyukqborA8GyU5cUxD
  • freezeAuthority=51QVCuHfL1FeNjd8BDeffCKhCcAYoULnVB3yjNhShiuK
  • defaultAccountState=initialized

Where it trades

VenueKind
Ondo Stocks platform (app.ondo.finance and GMTokenManager contracts)issuer primary
Nest Exchange (Binance MTF, ADGM), for eligible Binance account holdersexchange
Bitget (named launch partner)exchange
OKX (named launch partner)exchange
HTX Global (named launch partner)exchange
CoW Protocol (named launch partner)dex
1inch (named launch partner)dex

How it exits

PathSettlementMinimumFeeSettles in
Redeem with the issuer in its windowInstant atomic mint or redeem against an Ondo-signed quote through GMTokenManager during 24/5 sessions; select assets also in an Off-Hours session$10 bpsUSDon, USDC, USDT
Redeem in kindShare-for-token mint or redeem through Alpaca Instant Tokenization Network, for institutions Alpaca approves case by case (since 2026-09-21)underlying shares
Secondary market only; no issuer redemptionHolders without Ondo onboarding sell on exchanges or DEXs; the issuer redeems only after KYCUSDC, USDT

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

The file is public. The subscription checks it against each of your households and watches it daily. $49 per advisor per month, first 14 days free. Start the trial.