Eligibility file · Money-market fund

Sygnum FIUSD (Fidelity Institutional Liquidity Fund, US Dollar Fund, Class G Acc)

What the client owns

Claim to one Class G Acc unit of Fidelity Institutional Liquidity Fund plc, The United States Dollar Fund, an Irish UCITS low-volatility money market fund, held by Sygnum in its own name for the token holder. Third-party custodial: A custodian’s security entitlement in the form of a token; the holder’s claim is against the custodian.

Who may hold it

Not offered to US persons. No first purchase minimum. Sygnum says transfers are open only to professional investors fully onboarded with Sygnum under Swiss law, whose custodial wallets it whitelists after know-your-customer checks. The fund’s Class G units carry no minimum subscription or holding under the prospectus Sygnum cites; Sygnum has not published its own account terms. No published Sygnum document says whether U.S. persons may hold, and Fidelity’s site blocks automated reads of its prospectus. We use the stricter reading: non-U.S. only. Sygnum charges 0.20% to subscribe and 0.40% to redeem, on top of the fund’s 0.25% a year.

Who can freeze or claw back

ZKsync Era: can freeze a holder, pause transfers, claw back, gate who may hold, mint, change the code. A 3-of-6 multisig can change the code with no delay.
Arbitrum: can freeze a holder, pause transfers, claw back, gate who may hold, mint, change the code. A single key can change the code with no delay.

How a holder redeems

Redeem with the issuer in its window. The holder asks Sygnum to redeem; Sygnum burns the tokens, sells the fund units through J.P. Morgan, and credits the proceeds to the holder’s Sygnum account in dollars, another fiat currency, or crypto. The fund settles the same day and has several dealing cutoffs a day, 40 bps fee. Settles in USD.

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The verdict is on the memo: Sygnum FIUSD (Fidelity Institutional Liquidity Fund, US Dollar Fund, Class G Acc) Under review

Issuer

Sygnum Bank AG, a FINMA-supervised Swiss bank, as issuer of the ledger-based security; Fidelity Institutional Liquidity Fund plc, an Irish UCITS managed by Fidelity International, as issuer of the fund units Sygnum holds; J.P. Morgan SE, Dublin Branch as fund custodian

Registration

Other

Official record

Sygnum Bank AG issues the ledger-based security on chain; the fund’s own register, kept by J.P. Morgan Administration Services (Ireland), shows Sygnum as holder

Instruments

FIUSD

Chains

ZKsync Era, Arbitrum

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

The holder has a claim on Sygnum to deliver fund units that Sygnum holds in its own name; the holder is not a direct shareholder of the fund.

“Holders of the FIUSD token have the right to demand the delivery of the underlying assets – i.e. the ILF fund units – held by Sygnum on behalf of Arbitrum”

Sygnum Bank AG: FIUSD STEP 2 application to the Arbitrum DAO, 20 March 2025 (Wayback Machine copy, 25 July 2025) · Section E.2, Do investors have any shareholder, investor, creditor or similar rights? · words found 2026-09-23

Who may hold it

Professional investors fully onboarded with Sygnum under Swiss law.

“If enabled, token transfers are exclusively available to professional investors fully onboarded with Sygnum, according to Swiss Law.”

Sygnum Bank AG: FIUSD STEP 2 application to the Arbitrum DAO, 20 March 2025 (Wayback Machine copy, 25 July 2025) · Section H.2, whitelisting · words found 2026-09-23

First purchase minimum

The fund’s Class G units have no minimum subscription or holding.

“Per current prospectus, Class G Shares within the ILF Fund have no minimum initial subscription, holding, or subsequent subscription requirements.”

Sygnum Bank AG: FIUSD STEP 2 application to the Arbitrum DAO, 20 March 2025 (Wayback Machine copy, 25 July 2025) · Section C, Minimum/Maximum transaction size · words found 2026-09-23

Who it may be transferred to

Only between custodial wallets that Sygnum has whitelisted after its checks.

“Upon successful completion of these due diligence procedures, their custodial wallets are added to the whitelist.”

Sygnum Bank AG: FIUSD STEP 2 application to the Arbitrum DAO, 20 March 2025 (Wayback Machine copy, 25 July 2025) · Section H.2, whitelisting · words found 2026-09-23

How a holder redeems

The holder asks Sygnum, which burns the tokens and sells the units through J.P. Morgan.

“Upon receiving the request, Sygnum burns the tokens.”

Sygnum Bank AG: FIUSD STEP 2 application to the Arbitrum DAO, 20 March 2025 (Wayback Machine copy, 25 July 2025) · Section E.7, Redemption flow · words found 2026-09-23

Who keeps the official record

The token is a Swiss ledger-based security, a form of right the Code of Obligations ties to the ledger.

“The FIUSD tokens are issued as a ledger-based security under Swiss law in accordance with art. 973d et seqq. of the Swiss Code of Obligations.”

Sygnum Bank AG: FIUSD STEP 2 application to the Arbitrum DAO, 20 March 2025 (Wayback Machine copy, 25 July 2025) · Section E.3, legal structure · words found 2026-09-23

What the issuer says it can freeze or take back

Sygnum’s contracts let named roles make corrections; on chain they can freeze, pause, and move tokens between holders.

“Sygnum’s smart contracts include functions that allow specific users to make necessary corrections in a fully auditable manner.”

Sygnum Bank AG: FIUSD STEP 2 application to the Arbitrum DAO, 20 March 2025 (Wayback Machine copy, 25 July 2025) · Section E.12, Smart contract functions · words found 2026-09-23

Fact	Answer
Who onboards the holder	issuer
Voting rights	None
Distributions	reinvested
SIPC coverage of the wallet	No

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
ZKsync Era	Yes	Yes	Yes	Yes	Yes	A 3-of-6 multisig can change the code with no delay.
Arbitrum	Yes	Yes	Yes	Yes	Yes	A single key 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.

Chain	Key	What it can do	Held by	Address
ZKsync Era	Proxy admin	change the code	a 3-of-6 multisig	0xaf50…dbff
ZKsync Era	Issuer	mint new tokens	a single key	0x534a…1713
Arbitrum	Proxy admin	change the code	a single key	0x6177…e95f
Arbitrum	Issuer	mint new tokens	a single key	0x534a…1713

ZKsync Era: 3 contract reads, 5 functions in verified source, 2026-09-23

Read from the chain

eip1967.implementation=0x8dd51341147a2d50566b9910f515689d3decaee8
eip1967.admin=0xaf50a7d823f89e5dfbfcf3ff9817b370e1a3dbff
isPaused()=false

Read from verified source

confirmWhitelistContract in verified source 0x8dd5…aee8
batchToggleFreeze in verified source 0x8dd5…aee8
isNotPaused in verified source 0x8dd5…aee8
batchConfiscate in verified source 0x8dd5…aee8
mint in verified source 0x8dd5…aee8

Arbitrum: 3 contract reads, 5 functions in verified source, 2026-09-23

Read from the chain

eip1967.implementation=0x7616b08676117e1aab542e53fe3f7b12f7596d37
eip1967.admin=0x61776319fc4c120e9b1ec41306f2db968be1e95f
isPaused()=false

Read from verified source

confirmWhitelistContract in verified source 0x7616…6d37
batchToggleFreeze in verified source 0x7616…6d37
isNotPaused in verified source 0x7616…6d37
batchConfiscate in verified source 0x7616…6d37
mint in verified source 0x7616…6d37

Where it trades

Venue	Kind
Sygnum Bank	issuer primary

Redemption

Route	Settlement	Fee	Settles in
Redeem with the issuer in its window	The holder asks Sygnum to redeem; Sygnum burns the tokens, sells the fund units through J.P. Morgan, and credits the proceeds to the holder’s Sygnum account in dollars, another fiat currency, or crypto. The fund settles the same day and has several dealing cutoffs a day.	40 bps	USD

Review triggers

Sygnum publishes product terms that state who may hold, whether U.S. persons are barred, or its own minimum
The zkSync proxy admin or implementation changes, or supply returns to the Arbitrum contract, whose proxy admin is a single key
On-chain supply stops matching Fidelity’s published Class G Acc units in issue
Fidelity changes the Class G terms or the fund’s dealing cutoffs

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.

Date	Change
2026-09-23	Filed.

Sources

Sygnum Bank AG: FIUSD STEP 2 application to the Arbitrum DAO, 20 March 2025 (Wayback Machine copy, 25 July 2025) · primary · accessed 2026-09-23
Supports: ledger-based security under art. 973d CO, claim to delivery of fund units, fiduciary holding under Banking Act art. 16, one token per fund unit, professional investors onboarded with Sygnum, whitelisted custodial wallets, no Class G minimum, redemption flow, same-day fund settlement, fees, corrections by named roles, counterparties
Arbitrum forum: the same application at its original address · primary · accessed 2026-09-23
Supports: application original
PR Newswire: Sygnum tokenises Matter Labs treasury reserves in USD 6.9bn Fidelity MMF, 19 March 2024 · primary · accessed 2026-09-23
Supports: launch, Matter Labs USD 50 million, ZKsync Era
Sygnum: tokenization page, FIUSD entry (Wayback Machine copy, 16 April 2026) · primary · accessed 2026-09-23
Supports: traditional security token, money market fund
Fidelity International: USD LVNAV fund daily prices (overwritten daily; read for 22 September 2026) · primary · accessed 2026-09-23
Supports: Class G Acc ISIN IE00BNKLND78, NAV 12,033.69, 1,604.66 units in issue, net assets USD 19.3 million
ZKsync block explorer: verified SygnumTokenLatest implementation · secondary · accessed 2026-09-23
Supports: confiscate, toggleFreeze, pause, mint, upgradeable proxy

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