Eligibility file · Note

USDM1 (Republic of the Marshall Islands tokenized secured bonds, redeemable at one US dollar)

What the client owns

Republic of the Marshall Islands tokenized perpetual adjustable-rate secured bonds, par one US dollar, secured by short-dated US Treasuries pledged to the collateral agent. Issuer direct: The on-chain record is the securityholder file; the holder is the registered owner.

Who may hold it

Not offered to US persons. First purchase minimum not stated. The Republic sells USDM1 in continuous Reg S offerings and has not registered it under the US Securities Act. Its site says USDM1 may not be offered, sold, pledged or transferred in the United States or to US investors unless registered or exempt. Outside the Marshall Islands the Republic gives “controlled access” to qualified institutional counterparties, on request through M1X Global. The Republic publishes no minimum.

Who can freeze or claw back

Ethereum: can freeze a holder, claw back, mint, change the code. A single key can freeze a holder and claw back tokens.

How a holder redeems

Redeem with the issuer in its window. A holder may redeem each bond at any time for one US dollar; the trustee administers par redemption from the Treasury collateral. No cutoff, settlement time or fee is published. Settles in USD.

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: USDM1 (Republic of the Marshall Islands) Not approved

Issuer

The Republic of the Marshall Islands (Ministry of Finance, Banking & Postal Services), as sovereign issuer under a New York law indenture; Surus Trust Company (North Carolina) as trustee, collateral agent and custodian; M1X Global as the Republic’s exclusive services provider

Registration

Regulation S, offshore

Official record

None named. The bonds exist only in book-entry form recorded from token holdings; Surus Trust Company is trustee under the indenture

Instruments

USDM1

Chains

Ethereum

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

Each unit is a par-value bond of the Republic with a secured claim on the pledged US Treasuries.

“each unit of USDM1 represents a par-value sovereign obligation with enforceable rights against the sovereign, alongside a secured claim on the U.S. Treasury collateral.”

RMI Ministry of Finance: Financial Access and the Path to USDM1 (2025-12-15) · Part 6, The Instrument · words found 2026-09-23

Who may hold it

Non-US holders under Regulation S; outside the Marshall Islands, qualified institutional counterparties the Republic admits.

“the RMI is enabling controlled access to USDM1 for qualified institutional counterparties”

RMI Ministry of Finance: Financial Access and the Path to USDM1 (2025-12-15) · Part 6, International Inquiries · words found 2026-09-23

First purchase minimum

The Republic publishes no minimum.

Not stated in USDM1 home page, USDM1 disclosures, RMI Ministry of Finance: Financial Access and the Path to USDM1 (2025-12-15), Cleary Gottlieb: Republic of the Marshall Islands establishes program for continuous offerings of tokenized bonds (2025-11-19).

Who it may be transferred to

Tokens move freely on chain, but the bonds may not be offered, sold, pledged or transferred in the United States or to US investors unless registered or exempt.

“USDM1 may not be offered, sold, pledged or otherwise transferred in the United States or to US investors, unless they are registered, or exempt from, or not subject to, registration under the US Securities Act.”

USDM1 disclosures · Disclosures, first paragraph · words found 2026-09-23

How a holder redeems

A holder may redeem each bond at any time for one US dollar.

“holders will be able to redeem each of their bonds at any time for one U.S. dollar to liquidate their investments, similar to a stablecoin.”

Cleary Gottlieb: Republic of the Marshall Islands establishes program for continuous offerings of tokenized bonds (2025-11-19) · Announcement, second paragraph · words found 2026-09-23

Who keeps the official record

The bonds exist only as book entries recorded from token holdings on the chain.

“the bonds are issued in dematerialized (electronic) and uncertificated form only, recorded in book-entry form based on the holdings of tokens issued on a blockchain network.”

Cleary Gottlieb: Republic of the Marshall Islands establishes program for continuous offerings of tokenized bonds (2025-11-19) · Announcement, second paragraph · words found 2026-09-23

What the issuer says it can freeze or take back

The documents do not mention freezing; on Ethereum the owner key can freeze any address and grant the role that burns from any holder.

Fact	Answer
Who onboards the holder	issuer
Voting rights	None
Distributions	new tokens
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
Ethereum	Yes	No	Yes	No	Yes	A single key can freeze a holder and claw back tokens.

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, mint new tokens, freeze a holder	a single key	0xc8b6…ec99
Ethereum	Minter burner role	claw back tokens, mint new tokens	a contract run by a single key	0xcbd3…b7e7
Ethereum	Minter burner role	claw back tokens, mint new tokens	a contract run by a single key	0x2385…b64f

Ethereum: 2 contract reads, 4 functions in verified source, 2026-09-23

Read from the chain

eip1967.implementation=0x304c5dc51fd7f31dad838be89d6a68b05723351c
owner()=0xc8b6df21933cac084672d6af8cb859054d20ec99

Read from verified source

freeze in verified source 0x304c…351c
burn in verified source 0x304c…351c
mint in verified source 0x304c…351c
upgradeToAndCall in verified source 0x304c…351c

Where it trades

Venue	Kind
Republic of the Marshall Islands through M1X Global (institutional access on request)	issuer primary

Redemption

Route	Settlement	Settles in
Redeem with the issuer in its window	A holder may redeem each bond at any time for one US dollar; the trustee administers par redemption from the Treasury collateral. No cutoff, settlement time or fee is published.	USD

Review triggers

The Republic or M1X Global publishes the indenture, offering memorandum, a collateral report, or official contract addresses (Ketju would then add the Stellar and Solana contracts to the file)
The Ethereum owner 0xc8b6df21933cac084672d6af8cb859054d20ec99 freezes an address, grants MINTER_BURNER_ROLE to a new address, burns from a holder, or upgrades the implementation
A redemption at par is refused or delayed, or Surus Trust Company is replaced as trustee or collateral agent
The Republic registers USDM1 in the United States or names a US exemption for US holders
The program grows past its initial $100 million limit or the Republic changes the share of collateral yield it keeps

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 its one-dollar value. 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

Cleary Gottlieb: Republic of the Marshall Islands establishes program for continuous offerings of tokenized bonds (2025-11-19) · primary · accessed 2026-09-23
Supports: Reg S program, initial $100 million, perpetual adjustable-rate secured bonds, book-entry from token holdings, interest capitalized, redeem any time for one US dollar, Republic keeps a portion of collateral yield, first unit issued 2025-09-23
RMI Ministry of Finance: Financial Access and the Path to USDM1 (2025-12-15) · primary · accessed 2026-09-23
Supports: sovereign obligation plus secured claim on Treasuries, New York law indenture, waiver of immunity, Surus trustee, custodian and collateral agent, Fiscal Responsibility and Debt Management Act 2020, controlled access for qualified institutional counterparties, Lomalo wallet on Stellar
USDM1 disclosures · primary · accessed 2026-09-23
Supports: not registered under the Securities Act, no offer, sale or transfer in the US or to US investors unless exempt
USDM1 home page · primary · accessed 2026-09-23
Supports: issued by the Republic, perfected first-priority security interest under UCC, pays a sovereign coupon
Surus: trustee, custodian and collateral agent for USDM1 (2026-04-09) · secondary · accessed 2026-09-23
Supports: M1X Global exclusive services provider, Surus Trust Company North Carolina charter, collateral agent holds first-priority security interest
tZERO: sovereign digital bond collateral in broker-dealer custody (2026-06-04) · secondary · accessed 2026-09-23
Supports: issued on Stellar, Canton and Solana, held through tZERO Digital Asset Securities
USDM_V3 implementation on Ethereum (Blockscout verified source) · primary · accessed 2026-09-23
Supports: @author M1 Global; interest-bearing USDM1, owner freeze and thaw, MINTER_BURNER_ROLE burn from any holder, UUPS upgrade by owner, ownership cannot be renounced

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