Eligibility file · Commodity

Token Teknoloji Gram Gold and Gram Silver (GRAMG, GRAMS)

What the client owns

One gram of gold per token, which the issuer says it holds as collateral, mostly at the Central Bank of the Republic of Turkey; no document gives holders a claim on it; One gram of silver per token, which the issuer says it adds to its own vault or bank accounts for each token made; no document gives holders a claim on it. Not stated: The issuer’s documents do not say whether the chain or an off-chain register governs. Ketju records the date it checked.

Who may hold it

US retail investors. First purchase minimum not stated. State coverage not confirmed by the issuer. The user agreement defines a user as a natural person aged 18 or over who documents identity for every transaction. It names no excluded countries and does not mention US persons. The product pages give no minimum beyond a comparison table that says trading starts at 1 TL. In practice holders buy and sell the tokens only inside Bitlo, a Turkish exchange; on chain they sit in a handful of issuer and exchange wallets.

Who can freeze or claw back

Avalanche GRAMG: can freeze a holder, pause transfers, claw back, mint. A single key holds the owner key.
Ethereum GRAMG: can freeze a holder, pause transfers, claw back, mint. A single key holds the owner key.
Polygon GRAMG: can freeze a holder, pause transfers, claw back, mint. A single key holds the owner key.

How a holder redeems

Redeem with the issuer in its window. The issuer offers only one way to redeem: converting GRAMG or GRAMS to Turkish lira on bitlo.com. No document offers delivery of metal, and none states a minimum, fee, or timetable. Settles in TRY.

This file replaced an earlier version on 2026-09-24. Superseded to settle the allowlist the file had marked unverified. The contract keeps a KYC list, but both KYC checks in its transfer hook are commented out and the contract cannot be upgraded, so the list can never stop a transfer: no allowlist on Avalanche, Ethereum, or Polygon. 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: Token Teknoloji Gram Gold and Gram Silver (GRAMG, GRAMS) Not approved

Issuer

Token Teknoloji Anonim Şirketi (Istanbul, Turkey); no registration number or licence is published

Registration

Other

Official record

No transfer agent

Instruments

GRAMG GRAMS

Chains

Avalanche, Ethereum, Polygon

Reviewed

2026-09-24

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 product page says a gram of gold is held as collateral for each token; no agreement says whose it is or what the holder may claim.

“Üretilen her GRAMG karşılığında 1 gram fiziki altın teminat olarak tutulmaktadır.”

Token Teknoloji: Gram Gold (GRAMG) product page · Gram Altının Kripto Para Hali (translation: for each GRAMG produced, 1 gram of physical gold is held as collateral) · words found 2026-09-23

What the holder owns

The silver page says the token gives ownership directly to the holder; the published bank letters show the silver in the company’s own accounts.

“GRAMS, mülkiyet sahipliğini doğrudan kişiye vermektedir.”

Token Teknoloji: Gram Silver (GRAMS) product page · FAQ, GRAMS Neler Sunuyor? (translation: GRAMS gives ownership directly to the person) · words found 2026-09-23

Who may hold it

Users who declare they are over 18 and document their identity for every transaction; no countries are named.

“Kullanıcı, gerçekleştireceği tüm işlemler için kimlik ve gerekirse adres bilgilerini belgelemek zorundadır.”

Token Teknoloji: Kullanıcı Sözleşmesi (user agreement) · Section 4.14 (translation: the user must document identity, and address if needed, for all transactions) · words found 2026-09-23

First purchase minimum

No agreement states a minimum.

Account types

Natural persons only, by the user agreement’s definition of a user.

“Sözleşme’de bulunan hususları kabul eden gerçek kişiyi ifade eder.”

Token Teknoloji: Kullanıcı Sözleşmesi (user agreement) · Section 2, definition of Kullanıcı (translation: means the natural person who accepts the terms of the Agreement) · words found 2026-09-23

Who it may be transferred to

No agreement covers transfers; on chain the tokens move freely unless an address is frozen or the token is paused.

How a holder redeems

Only by converting to Turkish lira on Bitlo; no metal redemption is offered.

“GRAMG sahibi yatırımcılar varlıklarını kripto para alım satım platformu bitlo.com üzerinden Türk lirasına çevirebilir.”

Token Teknoloji: Gram Gold (GRAMG) product page · Türk Lirasına Çevirilebilir (translation: GRAMG holders can convert their holdings to Turkish lira on bitlo.com) · words found 2026-09-23

Who keeps the official record

No document says which record of holders governs.

Not stated in Token Teknoloji: Gram Gold (GRAMG) product page, Token Teknoloji: Gram Silver (GRAMS) product page, Token Teknoloji: Kullanıcı Sözleşmesi (user agreement), Token Teknoloji: Kullanım Koşulları (usage conditions), Token Teknoloji: Rezerv Kanıtları (reserve proofs), Wayback capture of 2026-04-15; the live page returns 404.

What the issuer says it can freeze or take back

The agreement lets the company cancel or suspend accounts without notice; on chain one key can freeze and pause and another can wipe any balance.

“Hesabı’nı/Hesapları’nı hiçbir bildirimde bulunmaksızın iptal etme, durdurma veya askıya alma hakkına sahiptir.”

Token Teknoloji: Kullanıcı Sözleşmesi (user agreement) · Section 4.15 (translation: has the right to cancel, stop or suspend the account(s) without any notice) · words found 2026-09-23

Fact	Answer
Who onboards the holder	issuer
Voting rights	None
Distributions	None
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.

Token	Chain	Freeze a holder	Pause	Claw back	Gate holders	Change the code	Keys held by
GRAMG	Avalanche	Yes	Yes	Yes	No	No	A single key holds the owner key.
GRAMG	Ethereum	Yes	Yes	Yes	No	No	A single key holds the owner key.
GRAMG	Polygon	Yes	Yes	Yes	No	No	A single key holds the owner key.

Who holds the keys

Ketju read every current holder of each power from the chain on 2026-09-24. 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.

Token	Chain	Key	What it can do	Held by	Address
GRAMG	Avalanche	Owner	grant and revoke these powers, decide who may hold	a single key	0xff80…b4fb
GRAMG	Avalanche	Admin role	grant and revoke these powers	a single key	0xd61c…3077
GRAMG	Avalanche	Admin role	grant and revoke these powers	a single key	0xff80…b4fb
GRAMG	Ethereum	Owner	grant and revoke these powers, decide who may hold	a single key	0xff80…b4fb
GRAMG	Ethereum	Admin role	grant and revoke these powers	a single key	0xd61c…3077
GRAMG	Ethereum	Admin role	grant and revoke these powers	a single key	0xff80…b4fb
GRAMG	Polygon	Owner	grant and revoke these powers, decide who may hold	a single key	0xd61c…3077

Avalanche GRAMG: 2 contract reads, 4 functions in verified source, 2026-09-24

Read from the chain

owner()=0xff80b391b286887d446b1124820f87d5b049b4fb
paused()=false

Read from verified source

abi:routescan:43114:0xae55ab6a966863cb4c774ba8e6c0a37cfbea01f9#freeze
abi:routescan:43114:0xae55ab6a966863cb4c774ba8e6c0a37cfbea01f9#pause
abi:routescan:43114:0xae55ab6a966863cb4c774ba8e6c0a37cfbea01f9#wipe
abi:routescan:43114:0xae55ab6a966863cb4c774ba8e6c0a37cfbea01f9#mint

Ethereum GRAMG: 2 contract reads, 4 functions in verified source, 2026-09-24

Read from the chain

owner()=0xff80b391b286887d446b1124820f87d5b049b4fb
paused()=false

Read from verified source

Polygon GRAMG: 2 contract reads, 4 functions in verified source, 2026-09-24

Read from the chain

owner()=0xd61c0129f6c35a675db6e2a067b31e75b2573077
paused()=false

Read from verified source

Where it trades

Venue	Kind
Bitlo (GRAMG-TRY, GRAMS-TRY and USDT pairs, custodial)	exchange

Redemption

Route	Settlement	Settles in
Redeem with the issuer in its window	The issuer offers only one way to redeem: converting GRAMG or GRAMS to Turkish lira on bitlo.com. No document offers delivery of metal, and none states a minimum, fee, or timetable.	TRY

Review triggers

The supply manager 0xff80b391b286887d446b1124820f87d5b049b4fb or compliance manager 0xd61c0129f6c35a675db6e2a067b31e75b2573077 (both single keys) changes, or a new contract replaces GRAMG or GRAMS
Token Teknoloji freezes or wipes an address, pauses a token, or turns on KYC gating in a new deployment
Supply appears on Ethereum or Polygon, where the same contracts held none on 2026-09-23
Token Teknoloji publishes token terms, a redemption process for metal, or a current reserve letter or audit (the last letters are from May and August 2024 and the reserve page returns 404)

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 once since filing it. Ketju keeps each earlier version as published, with the reason for the change.

Date	Change
2026-09-23	Filed.
2026-09-24	Revised. Superseded to settle the allowlist the file had marked unverified. The contract keeps a KYC list, but both KYC checks in its transfer hook are commented out and the contract cannot be upgraded, so the list can never stop a transfer: no allowlist on Avalanche, Ethereum, or Polygon.

Sources

Token Teknoloji: Gram Gold (GRAMG) product page · primary · accessed 2026-09-23
Supports: one gram of gold held as collateral per token, over 90% at the Turkish central bank, convertible to Turkish lira on bitlo.com, explorer links to the contracts
Token Teknoloji: Gram Silver (GRAMS) product page · primary · accessed 2026-09-23
Supports: silver added to the company vault per token, gives ownership directly to the person, explorer links to the contracts
Token Teknoloji: Kullanıcı Sözleşmesi (user agreement) · primary · accessed 2026-09-23
Supports: users aged 18 and over, user is a natural person, identity documents for every transaction, accounts cancelled or suspended without notice, no mention of reserve tokens or redemption
Token Teknoloji: Kullanım Koşulları (usage conditions) · primary · accessed 2026-09-23
Supports: no mention of reserve tokens, metal, or redemption, Turkish law, Istanbul courts
Token Teknoloji: Rezerv Kanıtları (reserve proofs), Wayback capture of 2026-04-15; the live page returns 404 · primary · accessed 2026-09-23
Supports: gold at Kuveyt Türk and Ziraat Katılım, and at the central bank through FATSİ, silver at Kuveyt Türk, VakıfBank, Ziraat Katılım and Akbank, bank letters of May and August 2024
GRAMG contract on Avalanche (Routescan verified source) · primary · accessed 2026-09-23
Supports: KYC checks commented out of _beforeTokenTransfer, freeze and pause by the compliance manager, wipe by the enforcement manager, mint and burn by the supply manager, not upgradeable

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