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Eligibility file · Mixed

ST0x tokenized stocks and ETFs (S01 Issuer GmbH debt tokens on Base; traded as wt- vault shares)

What the client owns
A holder is an unsecured creditor of S01 Issuer GmbH with a contractual right to one share per token; the shares the issuer holds are its own hedge and do not belong to the holder. 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. The tokens are not for US persons or any US address. S01 Issuer offers them publicly under the prospectus in Liechtenstein, Germany, Luxembourg, France, Spain and Italy to retail and professional investors, and elsewhere only under a prospectus exemption. No one onboards a holder: wt-tokens trade on public Raindex order books on Base, and the st0x.io site advertises its SGOV product with no KYC. Minting and redeeming run only through the issuer’s interface and need an account at a broker the issuer names; that broker applies its own KYC. The terms set the smallest mint at shares worth US $1.00 and the smallest redemption at tokens worth US $10.00. Holders warrant they are not sanctioned or resident in a comprehensively sanctioned country.
Who can freeze or claw back
Base wtSPYM: can mint, change the code. A 3-of-6 multisig can change the code with no delay.
Base wtSPYM: can pause transfers, claw back, mint, change the code. A 3-of-6 multisig can pause transfers. A 3-of-6 multisig can change the code with no delay.
How a holder redeems
Secondary market only; no issuer redemption. A holder sells the wt-token on Rain order books on Base (through st0x.io or any other interface) against USDC; liquidity comes from arbitrageurs who mint and redeem with the issuer. Settles in USDC.

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The verdict is on the memo: ST0x tokenized stocks (S01 Issuer GmbH) Not approved

Issuer
S01 Issuer GmbH (Berlin, HRB 270925 B; LEI 2549007E71R1GHH0R131; share capital EUR 25,000; wholly owned by $ Zero X Ltd, London); not licensed or supervised; holds its hedge in shares with US broker-dealers for its own account. SARK X (BVI) Ltd runs the st0x.io interface.
Registration
Other
Official record
No transfer agent
Instruments
wtSPYM wtCOIN wtSGOV wtFGI wtNKE wtGRND wtWEN wtNVDA
Chains
Base
Reviewed
2026-09-23
Next review
2027-01-15

Other programs tokenize the same securities. Every version side by side: COIN, SGOV, NKE, GRND, WEN, NVDA.

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 holder is an unsecured creditor of S01 Issuer GmbH with a contractual right to one share per token; the shares the issuer holds are its own hedge and do not belong to the holder.

“Holders are unsecured contractual creditors of the Issuer.”

ST0x FAQs · What do I own when I hold a token? · words found 2026-09-23

Who may hold it

Anyone outside the United States who is not sanctioned; no onboarding to hold or trade.

“THE PRODUCTS ARE NOT FOR DISTRIBUTION TO ANY U.S. PERSON OR ANY PERSON OR ADDRESS”

S01 Issuer GmbH, Base Prospectus, Program on the Issuance and Offer of Token (30 March 2026, approved by the FMA Liechtenstein, valid to 29 March 2027) · Important Information, General Sales Restrictions (p. 2) · words found 2026-09-23

First purchase minimum

Minting takes shares worth at least US $1.00; redeeming takes tokens worth at least US $10.00; trading has no minimum.

“The minimum Exchange Transaction size for the Issuer to convert Shares to Tokens is a quantity of Shares with an aggregate value of at least US $1.00”

S01 Issuer GmbH, Base Prospectus, Program on the Issuance and Offer of Token (30 March 2026, approved by the FMA Liechtenstein, valid to 29 March 2027) · General Terms and Conditions, clause 4.7(d) · words found 2026-09-23

Account types

Redemption needs an account at a broker the issuer designates; if the holder cannot pass that broker’s KYC, the issuer owes no other way to redeem.

“Should an Investor be unable to maintain or open an Account with any Eligible Broker due to circumstances within the Investor’s control”

S01 Issuer GmbH, Base Prospectus, Program on the Issuance and Offer of Token (30 March 2026, approved by the FMA Liechtenstein, valid to 29 March 2027) · General Terms and Conditions, clause 10.2(c) · words found 2026-09-23

Who it may be transferred to

The terms put no restriction on transfer; the contract owner can still freeze the whole token and confiscate balances.

“There are no restrictions on the free transferability of the Products.”

S01 Issuer GmbH, Base Prospectus, Program on the Issuance and Offer of Token (30 March 2026, approved by the FMA Liechtenstein, valid to 29 March 2027) · Summary, What are the Products? (p. 10) · words found 2026-09-23

How a holder redeems

A holder may ask at any time for delivery of the share through the issuer’s interface to an eligible broker account; there is no cash redemption unless the issuer suspends exchange and sells the shares.

“Investors are entitled to demand delivery of the Underlying from at any time.”

S01 Issuer GmbH, Base Prospectus, Program on the Issuance and Offer of Token (30 March 2026, approved by the FMA Liechtenstein, valid to 29 March 2027) · Summary, Rights attached to the Products (p. 10) · words found 2026-09-23

Who keeps the official record

The documents name no register; whoever controls a token on chain holds its rights against the issuer.

“the transferring Party shall be deemed to have transferred all rights and obligations against the Issuer”

S01 Issuer GmbH, Base Prospectus, Program on the Issuance and Offer of Token (30 March 2026, approved by the FMA Liechtenstein, valid to 29 March 2027) · General Terms and Conditions, clause 4.4 Crypto Token Transfers · words found 2026-09-23

What the issuer says it can freeze or take back

The issuer may confiscate tokens from any holder on a legal order and block transfers; on a security event it may freeze every transfer and reissue tokens.

“The Tokens include a confiscation functionality enabling the transfer of Tokens from any Investor to a designated”

S01 Issuer GmbH, Base Prospectus, Program on the Issuance and Offer of Token (30 March 2026, approved by the FMA Liechtenstein, valid to 29 March 2027) · Risk Factors, Transfer modality risks (p. 23) · words found 2026-09-23

FactAnswer
Who onboards the holderNo onboarding
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
wtSPYMBaseNoNoNoNoYesA 3-of-6 multisig can change the code with no delay.
wtSPYMBaseNoYesYesNoYesA 3-of-6 multisig can pause transfers. A 3-of-6 multisig can change the code with no delay.

Who holds the keys

Ketju read every current holder of each power from the chain on 2026-09-23. 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.

TokenChainKeyWhat it can doHeld byAddress
wtSPYMBaseBeacon ownerchange the codea 3-of-6 multisig0xe70d…d611
wtSPYMBaseOwnergrant and revoke these powers, pause transfersa 3-of-6 multisig0xe70d…d611
wtSPYMBaseBeacon ownerchange the codea 3-of-6 multisig0xe70d…d611
Base wtSPYM: 2 contract reads, 1 function in verified source, 2026-09-23
Read from the chain
  • eip1967.beacon=0x4c2d2d3bf1232bf0d3fb7123007a9b8444637bc8
  • 0x4c2d2d3bf1232bf0d3fb7123007a9b8444637bc8.implementation()=0x0d99e0174dbf885ced6ae8deb939b0f890450099
Read from verified source
Base wtSPYM: 3 contract reads, 3 functions in verified source, 2026-09-23
Read from the chain
  • eip1967.beacon=0xea084c8f4331cdf3328e772781b59f8a24f28f1a
  • 0xea084c8f4331cdf3328e772781b59f8a24f28f1a.implementation()=0x52174538a83b18462c5cf898016539b086c920c7
  • owner()=0xe70d821f3462a074e63b42d0aac6523faae1d611
Read from verified source

Where it trades

VenueKind
S01 Issuer GmbH Core Bridge interface (mint and redeem against shares at an eligible broker)issuer primary
Raindex order books on Base, via st0x.io (SARK X (BVI) Ltd) or other interfacesdex

Redemption

RouteSettlementMinimumSettles in
Secondary market only; no issuer redemptionA holder sells the wt-token on Rain order books on Base (through st0x.io or any other interface) against USDC; liquidity comes from arbitrageurs who mint and redeem with the issuer.USDC
Redeem in kindA holder unwraps the wt-token into t-tokens, sends them to the issuer’s wallet through its interface, and names an account at a broker the issuer designates. The issuer transfers the shares through a broker transfer system and then burns the tokens. It can take hours to weeks; the issuer may suspend exchanges on broker failure, trading halts, corporate actions or regulation, and may then sell the shares and pay stablecoins instead. The Final Terms set the redemption fee, and the issuer has not published them.$10shares at the holder’s broker

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 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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