Spiko US T-Bills Money Market Fund

SPIKO SICAV was incorporated on 15 May 2024. When Spiko announced USTBL on 12 June, the novelty was not a synthetic Treasury ticker. It was a USD share, FR001400ODM9, in a French UCITS money-market sub-fund whose registered shareholder list would be kept on public DLTs.

That order matters. The token represents the share; it does not create a separate promise to hold one dollar or hand a wallet a particular bill. The shareholder owns a proportional slice of the pooled UCITS assets and gets one vote per share. Legal title sits in the fund structure while the wallet carries its registry entry.

Twenty First Capital may place up to 100% of net assets in diversified short-term instruments issued by the U.S. government. The rules cap weighted average maturity at 60 days, weighted average life at 120 days and residual maturity at six months, while requiring daily and weekly liquidity buffers.

The target is the capitalized effective Fed Funds rate after fees over a recommended week. That is a management objective, not code-enforced interest. Net income and realized gains stay inside the share and move NAV. Low rates, costs or market disruption can pull performance below the benchmark and can reduce capital.

The 2026 prospectus names eight registers: Ethereum, Polygon, Arbitrum, Starknet, Base, Etherlink, Stellar and Solana. Token balances are public, though the register is said not to expose directly identifying personal data. An investor chooses a supported chain, but the Management Company must validate the address first.

That allowlist changes the meaning of 24/7 transfer. A token can cross between approved wallets without waiting for a securities depository, yet it cannot lawfully move to any arbitrary address. U.S. Persons are excluded. Even an OTC transfer is treated by the fund as a redemption followed by a subscription, preserving the controlled register behind the ERC-20-like surface.

Under the 1 September 2026 prospectus, Spiko Finance clears orders by 11:30 Paris time for the next same-day NAV; later orders and relevant French or U.S. holidays roll forward. Payment may use bank money or eligible electronic-money tokens. The manager may suspend that token route, and AML obligations can force redemption settlement back to a bank transfer.

Exceptional net redemptions can also meet a 10% gate. Unfilled portions carry forward, for at most 20 NAVs over three months and no more than one month. Those clauses are the difference between a liquid fund and an unconditional stablecoin redemption promise: the shareholder has a redemption process, not an autonomous right to make contract code deliver dollars at any second.

Twenty First Capital manages the portfolio. CACEIS Bank safeguards assets, monitors cash flows and checks management decisions; CACEIS Fund Administration keeps the books. Spiko Finance distributes shares, controls the DLT register and clears subscriptions and redemptions. The KID describes fund assets as insulated from a management-company failure, while still warning that custody and operations carry risk.

The published EVM implementation supplies the technical levers: restricted callers can mint, burn, pause, unpause, reset ownership and authorize a UUPS upgrade. Both sender and recipient face permission checks. This review did not independently identify every current human signer or equivalent administrator across all eight networks.

On 3 September 2026 Spiko’s data page showed NAV 1.0949 and a 0.25% management fee. The prospectus table separately states a management fee of 0.30% including tax and operating and other-service costs of up to 0.10% including tax, both based on net assets. The reviewed materials do not reconcile the displayed 0.25% with the stated 0.30%; the latter is not identified in that table as a maximum. Network costs and a possible wallet-recovery charge remain separate from the zero subscription and redemption commissions.

USTBL’s durable achievement is narrower and more interesting than ‘Treasuries on-chain.’ It keeps a regulated shareholder right legible while letting that record travel across several public networks. Its limits are equally legible: sovereign assets do not remove interest-rate risk, token transfer does not remove eligibility, and an admin-controlled register does not become permissionless because explorers can see it.