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Eligibility file · Note

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

What the client owns
The token is a structured note issued as debt by Ondo Global Markets (BVI) Limited, a BVI special purpose company. The holder does not own the share. 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. To mint or redeem directly, a holder needs Ondo onboarding (Persona KYC, signed Sales Terms, an allowlisted wallet), which Ondo offers only to institutions today. EEA retail investors may buy under the FMA base prospectus. Investors in the UK, Switzerland, Singapore, Hong Kong, Malaysia and Brazil need professional or qualified status. Holders who buy on secondary markets need no KYC to hold but must pass KYC to redeem.
Who can freeze or claw back
Ethereum SPYon: can pause transfers, claw back, gate who may hold, mint, change the code. A 4-of-7 multisig holds the compliance owner key. Code changes must pass through a timelock with a 2-hour delay.
BSC SPYon: can pause transfers, claw back, gate who may hold, mint, change the code. A 4-of-7 multisig holds the compliance owner key. Code changes must pass through 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.
Hyperliquid L1 CRCLon: can pause transfers, claw back, gate who may hold, mint, change the code (freeze unverified). A 4-of-7 multisig holds the compliance owner key. Code changes must pass through a timelock with a 2-hour delay.
How a holder redeems
Redeem with the issuer in its window. Onboarded holders mint or redeem instantly against an Ondo-signed quote through GMTokenManager in 24/5 sessions, and for some assets in an Off-Hours session. Settles in USDon, USDC, USDT.

In plain words on RIADeFi: Ondo Global Markets, explained.

This file replaced an earlier version on 2026-09-27. Superseded to add the Hyperliquid L1 (HyperEVM) control reading: the file listed the tokens there with no reading of who can freeze, pause, or claw them back, so a wallet holding one on that chain matched nothing. The terms and the claim model did not change. 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: Ondo Global Markets (Ondo Stocks) Not approved

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
2026-09-27
Next review
2027-03-27

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

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 token is a structured note issued as debt by Ondo Global Markets (BVI) Limited, a BVI special purpose company. The holder does not own the share.

“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

$1.00 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

Holders can always redeem instantly to USDon, and 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

FactAnswer
Who onboards the holderissuer
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
SPYonEthereumNoYesYesYesYesA 4-of-7 multisig holds the compliance owner key. Code changes must pass through a timelock with a 2-hour delay.
SPYonBSCNoYesYesYesYesA 4-of-7 multisig holds the compliance owner key. Code changes must pass through 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.
CRCLonHyperliquid L1UnverifiedYesYesYesYesA 4-of-7 multisig holds the compliance owner key. Code changes must pass through a timelock with a 2-hour delay.

Who holds the keys

Ketju read every current holder of each power from the chain on 2026-09-27. 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
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 ownerdecide who may hold, grant 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
CRCLonHyperliquid L1Beacon ownerchange the codea timelock with a 2-hour delay0x6253…0e83
CRCLonHyperliquid L1Compliance ownergrant and revoke these powersa 4-of-7 multisig0xa307…a913

Ketju could not read the role holders on BSC, Hyperliquid L1 from the public event indexes on its last check. The table shows only what Ketju confirmed.

Ethereum SPYon: 1 contract read, 4 functions in verified source, 2026-09-23
Read from the chain
  • compliance()=0x54a8757c2fef8649830b158a8c19d3a670e80318
Read from verified source
BSC SPYon: 4 contract reads, 4 functions in verified source, 2026-09-24
Read from the chain
  • eip1967.beacon=0xc046b05a920e4b412815934dd8e58904dda73315
  • 0xc046b05a920e4b412815934dd8e58904dda73315.implementation()=0x578f397ca4661d1db4d9a65065d6b284a1a850fd
  • compliance()=0x76be569c94c39a2e2492de2f4d1c253f348250d0
  • codehash(0x76be569c94c39a2e2492de2f4d1c253f348250d0)=0xd1a9f20a2777be18afb57eb9310f8481432c34a95ae187430bfb679863423977=codehash(1:0x54a8757c2fef8649830b158a8c19d3a670e80318)
Read from verified source
Solana SPYon: 3 contract reads, 0 functions in verified source, 2026-09-23
Read from the chain
  • mintAuthority=9foMHsSDq7nMg4WPusSz9eY7tyxyukqborA8GyU5cUxD
  • freezeAuthority=51QVCuHfL1FeNjd8BDeffCKhCcAYoULnVB3yjNhShiuK
  • defaultAccountState=initialized
Hyperliquid L1 CRCLon: 7 contract reads, 7 functions in verified source, 2026-09-27
Read from the chain
  • totalSupply()=0x0000000000000000000000000f1bffcf1ffb9000
  • decimals()=0x0000000000000000000000000000000000000012
  • compliance()=0xae79085ad94ac040f712a63aaeae707ec5ede4f6
  • eip1967.implementation=0x0000000000000000000000000000000000000000
  • eip1967.admin=0x0000000000000000000000000000000000000000
  • eip1967.beacon=0x258269e782ab73aca6c0574990ff29b79aafffb6
  • beacon.implementation()=0x0d25c65d0cc97af724ffd7a54eb287660e8dfad4
Read from verified source

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

Redemption

RouteSettlementMinimumFeeSettles in
Redeem with the issuer in its windowOnboarded holders mint or redeem instantly against an Ondo-signed quote through GMTokenManager in 24/5 sessions, and for some assets 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

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 settle the BSC freeze power the file had marked unverified. The BSC compliance view contract has no verified source of its own, but its code is the same as Ondo’s verified Ethereum contract apart from per-deployment constants; read through it, the BSC token has no freeze.
2026-09-27Revised. Superseded to add the Hyperliquid L1 (HyperEVM) control reading: the file listed the tokens there with no reading of who can freeze, pause, or claw them back, so a wallet holding one on that chain matched nothing. The terms and the claim model did not change.

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.