OpenEden TBILL
Arbitrum: can claw back, gate who may hold, mint, change the code. A 3-of-4 multisig holds the kycmanager owner key.
This file replaced an earlier version on 2026-09-23. Superseded to quote the issuer’s terms: the U.S. user agreement names Treasury Bills International Liquidity Limited as issuer, allows redemption up to T+3 and in other stablecoins or dollars, and reserves a freeze; no document read says the chain is the register, so the claim model is now Not stated. 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: OpenEden TBILL Approved with limits
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.
- Who may hold it
BVI Professional Investors and US Accredited Investors under Rule 501(a).
“The TBILL Vault is currently only available to “Professional Investors” as defined under the British Virgin Islands’ Securities and Investment Business Act 2010 (“SIBA”) and to US “Accredited Investors” within the meaning of Rule 501(a) of Regulation D promulgated under the Securities Act.”
OpenEden Docs: investor eligibility and onboarding · Investor Onboarding, first paragraph · words found 2026-09-23
- First purchase minimum
100,000 USDC for the first deposit; 1 USDC after that.
“Additionally, the first deposit must be at least 100,000 USDC, while subsequent deposits must be at least 1 USDC.”
OpenEden Docs: TBILL Subscriptions · Restrictions, Address Level · words found 2026-09-23
- Account types
Individuals and entities that are accredited investors; the documents do not name trusts or IRAs.
“You will not re-sell your Digital Tokens to an individual or entity that is not an “accredited investor” within the meaning of Rule 501(a) of Regulation D promulgated under the United States Securities Act of 1933, as amended, or any resident of a Restricted Territory.”
OpenEden: TBILL User Agreement (US), Treasury Bills International Liquidity Limited, linked from docs.openeden.com/tbill/legal/user-agreement · Section 1.3(d), Eligibility; Limitations · words found 2026-09-23
- Who it may be transferred to
Only to other whitelisted investors.
“An Investor may only transfer to other whitelisted Investors.”
OpenEden Docs: TBILL FAQ and minimum subscription · FAQ, ”Can TBILL tokens be transferred to others?” · words found 2026-09-23
- How a holder redeems
The holder requests redemption from a whitelisted wallet; requests queue first in, first out and are typically paid in USDC the next US business day.
“The requests in the redemption queue are processed in accordance with a First-In-First-Out (FIFO) model. Redemptions are typically processed on the next 1 U.S. business day.”
OpenEden Docs: TBILL redemptions · Redemption Queue · words found 2026-09-23
- Who keeps the official record
The documents we read do not state this.
Not stated in OpenEden Docs: TBILL structure and investor claim, OpenEden Docs: investor eligibility and onboarding, OpenEden Docs: TBILL FAQ and minimum subscription, docs.openeden.com, docs.openeden.com, docs.openeden.com, docs.openeden.com, docs.openeden.com, OpenEden: TBILL User Agreement (US), Treasury Bills International Liquidity Limited, linked from docs.openeden.com/tbill/legal/user-agreement.
- What the issuer says it can freeze or take back
The fund may freeze tokens sent to or received from a blocked address, and may freeze or surrender them on a government order.
“In the event that you send Digital Tokens to a Blocked Address, or receive Tokens from a Blocked Address, the Fund may freeze such Digital Tokens and take steps to terminate your Platform Account.”
OpenEden: TBILL User Agreement (US), Treasury Bills International Liquidity Limited, linked from docs.openeden.com/tbill/legal/user-agreement · Section 17, Blocked Addresses & Forfeited Assets · words found 2026-09-23
| Fact | Answer |
|---|---|
| Who onboards the holder | issuer |
| Voting rights | None |
| Distributions | reinvested |
| SIPC coverage of the wallet | No |
What the issuer filed with the SEC
A private offering files Form D with the SEC within 15 days of its first sale and amends it each year while it sells. The issuer signs it. It states the exemption relied on, the fund’s exclusion from the Investment Company Act (which decides who may buy), the smallest investment accepted, the amount sold, and how many investors hold.
EDGAR has no Form D for the TBILL vault or Treasury Bills International Liquidity Limited. The only OpenEden Form D is OpenEden Group Ltd’s own 2024 raise ($490,000 from four investors), which is not the vault. Searched 2026-09-24 for “Treasury Bills International Liquidity”, “OpenEden”, “TBILL”.
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.
| Chain | Freeze a holder | Pause | Claw back | Gate holders | Change the code | Keys held by |
|---|---|---|---|---|---|---|
| Ethereum | No | No | Yes | Yes | Yes | A 3-of-4 multisig holds the kycmanager owner key. |
| Arbitrum | No | No | Yes | Yes | Yes | A 3-of-4 multisig holds the kycmanager owner key. |
Who holds the keys
Ketju read every current holder of each power from the chain on 2026-09-23. 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.
| Chain | Key | What it can do | Held by | Address |
|---|---|---|---|---|
| Ethereum | Owner | grant and revoke these powers, decide who may hold | a 4-of-5 multisig | 0x8ec4…5844 |
| Ethereum | KycManager owner | decide who may hold, grant and revoke these powers | a 3-of-4 multisig | 0x498a…15aa |
| Arbitrum | Owner | grant and revoke these powers, decide who may hold | a 4-of-5 multisig | 0xca7f…1bf3 |
| Arbitrum | KycManager owner | decide who may hold, grant and revoke these powers | a 3-of-4 multisig | 0x95b5…e103 |
Ethereum: 3 contract reads, 4 functions in verified source, 2026-09-22
- kycManager()=0x51be497aced1a2c19f6151064301e356b020d947
- owner()=0x8ec4dd2df01c188ac5a5d870029e9cbb820d5844
- eip1967.implementation=0xc4545bf80f935894cbe138d86b506923dab7c048
- burnFrom in verified source 0xc454…c048
- reIssue in verified source 0xc454…c048
- kycManager in verified source 0xc454…c048
- upgradeTo in verified source 0xc454…c048
Arbitrum: 2 contract reads, 2 functions in verified source, 2026-09-22
- kycManager()=0x0d7690baa1008c8d3c5dae9d5033ff846738bafb
- eip1967.implementation=0x78365404fc5edabef6eca2f6b2f1ba1471727a07
- burnFrom in verified source 0x7836…7a07
- reIssue in verified source 0x7836…7a07
Where it trades
| Venue | Kind |
|---|---|
| OpenEden subscription and redemption | issuer primary |
Redemption
| Route | Settlement | Minimum | Fee | Settles in |
|---|---|---|---|---|
| Redeem with the issuer in its window | Requests queue first in, first out and are typically paid the next U.S. business day. The U.S. user agreement allows up to T+3 business days, and OpenEden offers instant USDC redemption within limits | $1 | 5 bps | USDC, other supported stablecoins, USD |
- The KYC manager, owner, controller, or implementation address changes on any deployed chain
- OpenEden publishes the XRPL, BSC, or Solana contract addresses in its own documentation; Ketju will then read those chains and add them
- The first-subscription minimum, the accredited-investor gate, or the redemption path changes in the issuer’s documents
- A missed eligible redemption, an unexplained NAV deficit, or a contract exploit
- OpenEden or the fund states whether the chain or the administrator’s register governs ownership; Ketju will then state the holder’s claim from that document
- The fund freezes or surrenders tokens under the blocked-address clause of the user agreement
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 revised this file once since filing it. Ketju keeps each earlier version as published, with the reason for the change.
| Date | Change |
|---|---|
| 2026-09-22 | Filed. |
| 2026-09-23 | Revised. Superseded to quote the issuer’s terms: the U.S. user agreement names Treasury Bills International Liquidity Limited as issuer, allows redemption up to T+3 and in other stablecoins or dollars, and reserves a freeze; no document read says the chain is the register, so the claim model is now Not stated. |
Sources
- OpenEden Docs: TBILL structure and investor claim · primary · accessed 2026-09-22
Supports: BVI professional fund, Treasury bill portfolio, transfer restrictions - OpenEden Docs: investor eligibility and onboarding · primary · accessed 2026-09-22
Supports: U.S. Accredited Investor, BVI Professional Investor, KYC and KYT, wallet whitelist, who may-hold - OpenEden Docs: TBILL FAQ and minimum subscription · primary · accessed 2026-09-22
Supports: $100,000 first subscription, 5 basis-point transaction fee, transfer - OpenEden Docs: TBILL redemptions · primary · accessed 2026-09-22
Supports: FIFO queue, next-business-day processing, NAV at processing, redemption - TBILL implementation on Ethereum (Sourcify exact match) · primary · accessed 2026-09-22
Supports: kycManager, burnFrom, reIssue, mintTo, upgradeTo - OpenEden Docs: TBILL Subscriptions · primary · accessed 2026-09-23
Supports: minimum - OpenEden: TBILL User Agreement (US), Treasury Bills International Liquidity Limited, linked from docs.openeden.com/tbill/legal/user-agreement · primary · accessed 2026-09-23
Supports: account types, freeze - docs.openeden.com · primary · accessed 2026-09-23
Supports: checked for record - docs.openeden.com · primary · accessed 2026-09-23
Supports: checked for record - docs.openeden.com · primary · accessed 2026-09-23
Supports: checked for record - docs.openeden.com · primary · accessed 2026-09-23
Supports: checked for record - docs.openeden.com · primary · accessed 2026-09-23
Supports: checked for record