WisdomTree Government Money Market Digital Fund (WTGXX)

The scheduled date is the outside bound. Kill criteria are checked every day, and a trigger reopens the memo that week.

APPROVED WITH LIMITS. WTGXX is the only issuer/RWA entry in this backlog structured as a registered US mutual fund rather than a private placement: it is a series of WisdomTree Digital Trust, an SEC-registered investment company (CIK 1859001), managed by WisdomTree Digital Management with Voya Investment Management as sub-adviser, investing in US Treasury obligations targeting a stable $1.00 NAV. Unlike BlackRock BUIDL, Circle USYC, Ondo Global Markets, and Anemoy/JTRSY — all already rejected in this registry on access grounds — WTGXX is open to US retail investors through the WisdomTree Prime app with a $1 minimum, same-day 1:00pm ET NAV cutoff, and no shareholder fees. Blockchain (Ethereum and Stellar) is explicitly a mirror, not the books of record: the fund’s SEC-registered transfer agent, WisdomTree Transfers, maintains the Official Record and is contractually authorized to overwrite the on-chain Secondary Record when the two conflict — a materially different, more investor-protective control model than a smart-contract-only freeze function. The cap reflects a young track record (the fund launched October 2023), incomplete confirmed state-by-state retail availability, and an unrelated but real 2024 SEC enforcement action against WisdomTree Asset Management for ESG fund mislabeling.

Kill criteria: the events that revoke this verdict
• Full retail state coverage confirmed to include the intended client population, or a documented state gap that excludes a specific proposed client
• Twelve consecutive months with no NAV break, redemption suspension, or transfer-agent Official Record correction affecting client positions
• Any WisdomTree Digital Trust-specific SEC enforcement action, as opposed to the unrelated 2024 ETF matter
• The equity-exposed SPXUX or another sibling fund is inadvertently included in a client allocation intended for WTGXX

The research file

What the tracked figure actually represents

DefiLlama’s ”wisdomtree” TVL is not one fund: roughly 97% ($752M) is WTGXX itself on Ethereum, with the remaining ~$24M spread across eight smaller sibling funds on Stellar — including FLTTX, WTSYX, TIPSX, WTLGX, and notably SPXUX, an S&P 500 tracker fund, which is an equity product, not a money-market instrument. This memo and its approval scope cover WTGXX specifically, the dominant holding; the smaller sibling funds, and especially the equity-exposed SPXUX, are out of scope for this tokenized-rwa exposure classification and should not be treated as covered by this approval.

Legal structure and books of record

WTGXX is confirmed directly from its SEC prospectus (EDGAR filing 000121465923015364) to be a series of WisdomTree Digital Trust, a registered investment company under the Investment Company Act of 1940 — the same regulatory category as a conventional mutual fund, distinct from every Reg D/Reg S private-placement structure already rejected in this registry’s issuer/RWA batch. WisdomTree Transfers, Inc. (formerly Securrency Transfers, acquired and renamed by WisdomTree) is the SEC-registered transfer agent and maintains the ”Official Record” of share ownership; blockchain entries are a reconciled ”Secondary Record.” The prospectus states plainly: ”In the event of a conflict between the transaction history on the applicable blockchain and the records maintained by the Transfer Agent, the Transfer Agent shall update the blockchain record as necessary” — a correction mechanism, not a discretionary freeze.

Eligibility and control

Minimum investment is $1, distributed to US persons over 18 through the WisdomTree Prime retail app; a separate WisdomTree Connect channel serves institutional users. Retail state coverage expanded from 21 states at the 2023 launch to at least 41 states plus New York by a later press release, but a current full-50-state count could not be confirmed, so a client in an uncovered state cannot be assumed to have access. The prospectus reserves standard money-market-fund control rights: involuntary redemption of an account for suspected fraud or unmet KYC requirements, liquidation of below-minimum balances after written notice, and suspension of purchase orders under AML rules — conventional fund-administration authority, not an unusual freeze power.

Redemption

Same-day NAV cutoff at 1:00pm Eastern for both purchases and redemptions (earlier if a relevant valuation venue closes sooner), confirmed directly from the prospectus. No shareholder fees; the management fee is 0.25% of average daily net assets. This is materially faster and more predictable than the discretionary or capacity-limited ”near instant” redemption language this registry found insufficiently disclosed in BUIDL and USYC. WisdomTree has announced a roadmap toward 24/7 trading and instant settlement for tokenized fund shares; that is a forward-looking initiative, not the current mechanic, and this memo does not rely on it.

Track record and regulatory context

No WTGXX-specific incident, NAV break, or redemption suspension was found. The fund is young — prospectus dated October 2023 — and TVL has grown rapidly, reportedly over 700% since May 2026, which this review treats as a growth signal to monitor rather than an incident. WisdomTree Asset Management Inc. (the parent, not the digital-fund entity) paid a $4M SEC penalty in October 2024 for mislabeling three unrelated ETFs’ ESG exclusions — a real compliance-culture data point, though not a digital-fund-specific failure. Separately, the SEC granted exemptive relief to the WisdomTree Treasury Money Market Digital Fund in February 2026 and met with WisdomTree’s Crypto Task Force in August 2026 — active regulatory engagement, not enforcement.

Comparison and decision

Against Franklin Templeton’s BENJI, the other major ’40-Act-registered tokenized money market fund, WTGXX shares the same regulatory category and retail-open, same-day-redemption structure — both stand apart from Reg D private funds like BUIDL. Against every other entry in this issuer/RWA batch, WTGXX is the first product this review can actually recommend to this registry’s US mass-affluent client base without an access barrier. The cap reflects genuine open items — incomplete state coverage confirmation, a young track record, and an unrelated parent-level enforcement history — rather than a structural defect in the fund itself.

Sources

The claims above trace to these. Where a number could not be independently verified, the thesis says so.

• WisdomTree Government Money Market Digital Fund — SEC prospectus · primary · accessed 2026-08-17
  Supports: registered investment company status, Official Record vs Secondary Record, transfer agent conflict-resolution authority, same-day NAV cutoff, minimum investment, fees, involuntary redemption rights
• DefiLlama — WisdomTree protocol data · secondary · accessed 2026-08-17
  Supports: chain and fund TVL breakdown
• WisdomTree Transfer Agency and Services Agreement — SEC filing · primary · accessed 2026-08-17
  Supports: transfer agent identity, agreement terms
• SEC — WisdomTree ESG mislabeling enforcement action · primary · accessed 2026-08-17
  Supports: $4M penalty, unrelated ETF mislabeling, parent-entity compliance history
• Stellar — WisdomTree Prime state availability statement · secondary · accessed 2026-08-17
  Supports: retail state coverage
• eco.com — top tokenized treasury funds comparison · secondary · accessed 2026-08-17
  Supports: ’40 Act registered vs Reg D private placement comparison

Inherited controls

The verdict above grades the protocol layer. Every position also inherits the asset it holds and the chain it settles on. The least safe layer sets the position’s grade, and the position table names which one that is.