Reviewed, not listed

0x Protocol ZRX

Decided 2026-09-14 · due 2026-10-14

The 0x terms are entered into by ZeroEx Inc. and affiliates including ZeroEx International SEZC (Cayman), so the carve-out would apply; ZeroEx, Inc. is a Delaware corporation per the New York DOS record. No current headquarters is established: 0x describes itself as a globally remote team, and the only addresses are a 2022 Form D (San Francisco, over three years old) and state tax records. Founders' US status and current roles, and any regulator-record engagement, are also not established.

Across Protocol ACX

Decided 2026-09-14 · due 2026-10-14

The Across interface is provided by Risk Labs, which EDGAR records as a Cayman Islands exempted company (Form D, 2018), and Risk Labs Foundation calls itself the team behind Across. That Form D gives a New York principal address (259 Bowery) for Risk Labs and its directors Hart Lambur and Xuelin Lu, and the Delaware affiliate Risk Labs USA, Inc. uses Xuelin Lu at the same address as its New York process agent. Confirm that Risk Labs USA, Inc. employs the team and is the principal contributor, and its current headquarters.

ALEO ALEO

Decided 2026-09-14 · due 2026-10-14

Aleo's structure is US-based: Aleo Network Foundation is a Delaware nonstock corporation headquartered in the United States, and Provable Inc., which builds Aleo developer tools, is a Delaware corporation with a Reno, NV address. Aleo Systems, Inc., which aleo.org's terms still name as the site operator, filed a 2022 Form D as a Delaware corporation with a Reno address. Still missing: Test 2 or Test 3 evidence (founders' US status and current roles, or regulatory engagement), confirmation that Provable Inc. is the former Aleo Systems Inc. and Aleo's principal contributor, and a foundation address that is not the Cheyenne mail suite on file with the IRS.

Ankr Network ANKR

Decided 2026-09-14 · due 2026-10-14

Ankr's terms and privacy policy name Ankr Inc. as the website owner and service provider, based in California, but give no state of incorporation or street address; ankr.com's about and token pages blocked retrieval. The ANKR token issuer, and any offshore entity, is not identified. Establish Ankr Inc.'s registration and physical headquarters, the ANKR issuer, and founder roles.

Arcblock ABT

Decided 2026-09-14 · due 2026-10-14

ArcBlock Inc, a Delaware corporation, operates the ArcBlock website on behalf of ArcBlock Foundation, Limited, a Singapore company limited by guarantee, so any listing requires the carve-out pathway. ArcBlock Inc's only address evidence is its 2017 Form D (Bellevue, WA), which is too old to prove a current headquarters. No Test 2 or Test 3 evidence was found, and the foundation's token-issuer role is not confirmed.

Arkham ARKM

Decided 2026-09-14 · due 2026-10-14

Arkham Intelligence, Inc. operates Arkham Intel, but its legal pages give only a Dallas PMB and a Delaware registered-agent address, which are not a physical headquarters, and do not state its state of incorporation. The privacy policy also names an Arkham Foundation, whose jurisdiction and role in issuing ARKM are not established.

Audius AUDIO

Decided 2026-09-14 · due 2026-10-14

Audius, Inc. filed a 2020 Form D as a Delaware corporation, but its only address was a 548 Market St. suite number in San Francisco, a mail-receiving address. Audius is now stewarded by the Open Audio Foundation and supported by Tiki Labs, Inc. Neither's jurisdiction, headquarters, or relationship to Audius, Inc. is established, and Audius's legal pages did not load for review.

Avantis AVNT

Decided 2026-09-14 · due 2026-10-14

Avantis (rebranding to Veranta on 2026-09-14) is operated by Veranta Labs, Inc and the Veranta Foundation (Cayman Islands, contracting party and data controller). A Form D shows Lumena Labs, Inc. (Delaware, Menlo Park, CA), formerly Avantis Labs, Inc.; if documents tie that company to Veranta Labs, Inc and name it the principal contributor, a foundation carve-out may qualify.

Basic Attention BAT

Decided 2026-09-14 · due 2026-10-14

BAT Rewards terms are issued by Brave Software International SEZC (Cayman Islands), so the foundation carve-out applies with Brave Software, Inc. as the US contributor. Brave Software, Inc. is a Delaware corporation with its principal place of business in San Francisco (its own 2026 federal complaint) at 48 2nd St, which passes Tests 1 and 4. Neither Test 2 nor Test 3 is met yet: co-founder and CTO Brian Bondy's US status is not established (so only 1 of 2 founders qualifies), and no regulator-record engagement or engineering-majority evidence was found.

Cardano ADA

Decided 2026-09-14 · due 2026-10-14

The Cardano Foundation is Swiss, so the carve-out requires a US principal contributor; the Grayscale S-1/A calls IOG a principal research and engineering contributor. Sources conflict on that entity: in a July 2025 notice of removal, IOG's counsel says Input Output Global, Inc. is a Wyoming corporation (formerly Delaware) with its principal place of business in Colorado, alongside Singapore and Hong Kong affiliates, while the October 2025 S-1/A calls Input Output Global, Inc. a Cayman Islands company. Resolve the conflict with a Wyoming registry record, confirm which IOG entity employs the Cardano engineering team, and establish Test 2 or 3.

Celo CELO

Decided 2026-09-14 · due 2026-10-14

Celo's core developer, cLabs, Inc. d/b/a Celo Core Co., says it is based in California with US headquarters, which is project-only evidence. Its state of incorporation, a physical headquarters address, the jurisdiction of the Celo Foundation, and any Test 2/3 evidence are not yet documented.

Clearpool CPOOL

Decided 2026-09-14 · due 2026-10-14

Clearpool's platform terms name CP Clearpool Investment Inc. as the operator but do not state its jurisdiction or address. No US headquarters, US registration or US team has been documented, and the terms' restricted-country list does not exclude the US. A non-US finding is likely, but no source yet states the jurisdiction.

Coinbase Wrapped BTC CBBTC

Decided 2026-09-14 · due 2026-10-14

Coinbase, Inc. issues cbBTC and holds the backing BTC. Coinbase is remote-first and states it maintains no headquarters; the methodology accepts remote-first companies whose executive team and majority of full-time employees are US-based, so a decision awaits evidence of executive and workforce location.

Constellation DAG

Decided 2026-09-14 · due 2026-10-14

Constellation Network, Inc. is a Delaware corporation headquartered in San Francisco (AIAI Holdings prospectus, May 2026). It develops the Hypergraph network and holds internally generated DAG tokens, and it has been a subsidiary of Nasdaq-listed AIAI Holdings Corporation (Dallas, TX) since May 6, 2026. Tests 1 and 4 are met at the primary tier. Its subsidiary Constellation Foundation Company Limited has no stated jurisdiction (likely non-US, which would force the carve-out), and no Test 2 or Test 3 evidence was found.

Creditcoin CTC

Decided 2026-09-14 · due 2026-10-14

Creditcoin's websites and services are operated by Creditcoin OÜ, an Estonian-form private limited company, so listing needs a US principal contributor. Gluwa, Inc. is shown as an affiliated company and hosts the Creditcoin code, but its US state registration, headquarters and principal-contributor role are not yet documented.

Dash DASH

Decided 2026-09-14 · due 2026-10-14

Dash Core Group, Inc. is the main network-funded developer. Its terms (revised 2019) choose Arizona law and a Phoenix venue, but that is not evidence of where it is headquartered or incorporated. We found no current headquarters or state-registration record for DCG, and its listed team (CTO, core developers) does not establish US-based operations. Needs DCG's incorporation record, a current physical headquarters, and evidence of where its engineering is based.

Doodles DOOD

Decided 2026-09-14 · due 2026-10-14

A 2022 Form D shows Doodles Super Holdco, LLC as a Delaware entity with Julian Holguin, Jordan Castro, and Evan Keast as executive officers, listing a Dallas apartment address. The DOOD token issuer and its jurisdiction, the current operating company's headquarters, and founders' current roles and US status are not established; doodles.app legal pages were blocked by a bot checkpoint.

Figure Heloc FIGR_HELOC

Decided 2026-09-14 · due 2026-10-14

Editorial scope question: this asset is a Provenance Blockchain scope for tokenized HELOC loans (tokenized private credit), not a freely traded coin. The sponsor, Figure Technology Solutions, Inc., is a Nevada corporation (redomiciled from Delaware in May 2025) headquartered in New York. The entity does not yet clearly pass: no document names the token's issuing entity, co-founder Michael Cagney is described only as a board member, and no regulator-record engagement or strong operations evidence was gathered for Test 2 or 3.

Frax (prev. FXS) FRAX

Decided 2026-09-14 · due 2026-10-14

The token (formerly FXS) is Frax's governance token, and Frax's documentation describes Safes controlled by onchain governance and an unnamed "Frax team"; no legal entity is named as its issuer or principal developer. The only disclosed Frax legal entity is Financial Reserves and Asset Exploration Inc ("Frax Inc."), a Delaware corporation named as the frxUSD issuer, and no headquarters evidence was found for it. Establish whether Frax Inc. or another entity develops the Frax protocol, and its registration and headquarters.

Frax Ether FRXETH

Decided 2026-09-14 · due 2026-10-14

Frax's documentation says the Frax protocol issues frxETH, minted through its frxETHMinter contract; no legal entity is named as the issuer or developer of frxETH. The only disclosed Frax legal entity is Financial Reserves and Asset Exploration Inc ("Frax Inc."), a Delaware corporation named as the issuer of a different token, frxUSD, and no headquarters evidence was found for it. Establish which entity issues and maintains frxETH, and where it is registered and headquartered.

GALA GALA

Decided 2026-09-14 · due 2026-10-14

Blockchain Game Partners, Inc. d/b/a Gala Games is a Wyoming corporation per federal court filings (D. Wyo. 2023–2024), which place its principal office in Sheridan, Wyoming, a registered-agent hub, so a physical headquarters is not established. Founders Eric Schiermeyer and Wright Thurston have litigated against each other, and no current officer roster, US principal operations, or regulator-record engagement is documented.

Harmony ONE

Decided 2026-09-14 · due 2026-10-14

Harmony’s legal documents name Simple Rules Company as the company behind Harmony, with Delaware governing law and Santa Clara County courts, but its state of registration and headquarters were not found (no EDGAR, NY, CO or TX match). A Harmony Foundation of unknown jurisdiction funds the ecosystem, and harmony.one now redirects to a 1.country app.

Horizen ZEN

Decided 2026-09-14 · due 2026-10-14

Horizen is stewarded by Horizen Foundation, a Cayman Islands foundation, so listing requires a US principal contributor. Horizen Labs, Inc. is a Delaware corporation with a Texas registration and an Austin mailing address, but its site lists offices in New York, San Juan, Milan, and Singapore. It shared Horizen development with the Foundation as of 2021. Needs a current statement that Horizen Labs is Horizen's principal contributor, a physical US headquarters, and evidence that co-founders Robert Viglione and Rolf Versluis still hold operational roles or that operations are US-based.

Hyperlane HYPER

Decided 2026-09-14 · due 2026-10-14

HYPER is issued by the Developer's Eminence Foundation (d/b/a Hyperlane Foundation), a Cayman Islands foundation company, so only the carve-out could apply. Its MiCA white paper names two development teams, Abacus Works, Inc (Stamford, CT) and Abacus Skunkworks Ltd (London); Connecticut's registry records Abacus Works, Inc. as a Delaware corporation with a revoked CT registration. Confirm Abacus Works' current HQ, that it is the principal contributor, and US founders or operations.

io.net IO

Decided 2026-09-14 · due 2026-10-14

io.net's terms and privacy policy name IO.NET Inc., a Delaware corporation, as operator, but neither gives a headquarters address, and no filing or independent source for a US headquarters was found. $IO tokens are distributed by the Internet of GPUs Foundation, whose jurisdiction is not established; a non-US foundation would require the carve-out pathway. No Test 2 or Test 3 evidence was found.

Jito JTO

Decided 2026-09-14 · due 2026-10-14

Jito Labs, Inc. is a Delaware corporation that developed the Jito stake pool and StakeNet; the Jito Foundation is a Cayman Islands foundation company, so the carve-out applies. Jito Labs has no current physical headquarters on record: its Form Ds (Arlington, VA) date from 2021–2022, and its Texas record gives an Austin PMB. The Foundation's December 2025 announced return of core operations to the US is not yet documented.

Litecoin LTC

Decided 2026-09-14 · due 2026-10-14

litecoin.com is run under Litecoin Foundation Limited, which follows Singapore's data-protection law, so any listing would need the foundation carve-out. The US affiliate, Litecoin Foundation Inc (a 501(c)(3), Santa Monica), gives only a numbered-unit address (2219 Main St #584) that looks like a mail drop, its state of incorporation is not shown, and no US entity is shown to be the principal contributor to volunteer-run Litecoin Core. To decide, we need Litecoin Foundation Inc's physical office and incorporation record, plus evidence of who maintains Litecoin Core.

Loan Protocol LOAN

Decided 2026-09-14 · due 2026-10-14

Loan Protocol is presented on Metallicus's website alongside Metal X Lending, and Metallicus, Inc. is a Delaware corporation headquartered in San Francisco (listed separately for MTL, METAL and XPR). No source yet names the entity that issued LOAN or states that Metallicus operates the protocol, so the Metallicus facts cannot yet be attributed to LOAN.

Melania Meme MELANIA

Decided 2026-09-14 · due 2026-10-14

The melaniameme.com terms (last modified April 4, 2025) name MKT World, LLC as owner of the site and state that it does not engage in efforts to develop the coin. MKT World, LLC's state of formation, headquarters, and responsible team are not stated and were not found in the NY, CO, OR, or TX registries or EDGAR.

Nano XNO

Decided 2026-09-14 · due 2026-10-14

The Nano Foundation stewards Nano, and founder Colin LeMahieu and George Coxon (UK academic affiliations) serve as its directors voluntarily. nano.org discloses no legal form, jurisdiction, or address for the Foundation. Needs the Foundation's registration record and headquarters to decide whether a US entity is the principal contributor.

Nockchain NOCK

Decided 2026-09-14 · due 2026-10-14

Nockchain is a fair-launch ZK proof-of-work chain with no pre-mine, first built by Zorp Corp, which mined about 603M NOCK. Zorp Corp’s jurisdiction and headquarters are not stated anywhere found. A Texas Comptroller record lists a foreign-incorporated "ZORP CORP" in Tyler, TX, but nothing links it to Nockchain’s developer.

Onyxcoin XCN

Decided 2026-09-14 · due 2026-10-14

Onyx's whitepaper says the network is governed by the Onyx DAO of XCN holders, and its sites carry only "Onyx Protocol" with no legal entity named. Onyx says it has acquired Chain's technology platform, so an operating entity likely exists, but its name, jurisdiction and headquarters are not documented; if none is identified, XCN is not eligible.

Orca ORCA

Decided 2026-09-14 · due 2026-10-14

Zagreus Services LLC (d/b/a Orca Creative), a Delaware LLC registered in New York, tells the SEC Crypto Task Force it is a developer of the Orca Protocol, first built by two American software developers, but no headquarters evidence was found for it. The orca.so terms name only "Orca" under Cayman Islands law, and the ORCA token issuer is not identified. Confirm Zagreus's physical headquarters and founders, and identify the ORCA issuer and any offshore entity.

Orchid Protocol OXT

Decided 2026-09-14 · due 2026-10-14

Orchid Labs Inc. filed Form Ds in 2017–2018 as a Delaware corporation using a 182 Howard Street #423 address in San Francisco. Those filings are too old to prove a current headquarters. Orchid's current privacy policies are issued by "Orchid Technologies" with no legal form, jurisdiction, or address, and its relationship to Orchid Labs Inc. and to the OXT token is not established.

Origin Protocol OGN

Decided 2026-09-14 · due 2026-10-14

Tagged Made in America by CoinMarketCap; queued for evaluation against the methodology. Operating entity, jurisdiction, and headquarters not yet researched. The provider tag is not a USCC determination.

PHALA PHA

Decided 2026-09-14 · due 2026-10-14

Phala Cloud is operated by Hashforest Technology LLC under California-law terms, but the LLC’s state of formation and headquarters were not found (no EDGAR, NY, CO, OR or TX registry match), no entity is named as PHA token issuer or foundation, and the named co-founders (Marvin Tong, Hang Yin) are former Tencent/Didi staff with no US-person evidence.

Pi Network PI

Decided 2026-09-14 · due 2026-10-14

Pi Network says it is operated by Pi Community Company, which owns the Pi trademarks, and SocialChain Inc., with its headquarters in Silicon Valley, and founders Nicolas Kokkalis and Chengdiao Fan are Stanford PhDs who lead technology and product. Neither entity's jurisdiction or physical address is disclosed, the terms name only a California-law and San Francisco venue clause, and no SEC or state registry record was found. Needs registration records for both entities and evidence of which one issues PI.

PolySwarm NCT

Decided 2026-09-14 · due 2026-10-14

PolySwarm is operated by Swarm Technologies Inc. Its October 2025 privacy policy gives only a 548 Market Street suite number in San Francisco (a mail-receiving address), and its 2018 terms give a San Juan, Puerto Rico notice address. Neither is current physical-headquarters evidence, and neither page states a state of incorporation (a Delaware governing-law clause does not count). The NCT token issuer is not established.

PONKE PONKE

Decided 2026-09-14 · due 2026-10-14

The ponke.xyz terms state Ponke is operated by Helmet Studios LLC and select US and Wyoming law with Wyoming venue (a governing-law clause, not formation evidence). Helmet Studios LLC's state of formation, headquarters, and named team are not established; the Wyoming registry could not be queried and the name was not found in NY, CO, OR, TX registries or EDGAR.

Propy PRO

Decided 2026-09-14 · due 2026-10-14

PRO is issued by Propy, Inc., a Delaware corporation whose August 2026 Form D gives its principal place of business as 490 Post Street, San Francisco, so Tests 1 and 4 are met on primary documents. Neither US founders (Test 2) nor US primary operations on a regulator or court record (Test 3) are documented yet; candidates are state title and escrow licences for Propy's title subsidiaries and the S.D. Florida case Herzbrun v. Propy, Inc.

Pudgy Penguins PENGU

Decided 2026-09-14 · due 2026-10-14

PENGU's MiCA white paper names Simple Action Limited (BVI Company No. 2019801, registered and head office in Tortola, no current employees) as token issuer, which requires a US principal contributor under the carve-out. An SEC S-1 calls Pudgy Penguins the public identity of LSLTT Holdings LLC and a Bullish SEC filing calls Igloo Inc. its owner, but neither entity's state of formation or HQ, nor a project statement naming a US principal contributor, is established; pudgypenguins.com legal pages were blocked (HTTP 403).

ResearchCoin RSC

Decided 2026-09-14 · due 2026-10-14

ResearchHub Technologies, Inc. filed a 2025 Form D as a Delaware corporation with Brian Armstrong as an executive officer, but its only address is a 548 Market Street suite number, a mail-receiving address rather than a physical headquarters. ResearchCoin is deployed and governed through the ResearchHub Foundation, whose legal form and jurisdiction are not established. No Test 2 or Test 3 evidence was found.

Reserve Rights RSR

Decided 2026-09-14 · due 2026-10-14

Reserve.org and app.reserve.org are operated by ABC Labs, LLC, which contributes to development of the Reserve protocols. A Delaware-formed ABC Labs, LLC registered in New York in August 2025, but nothing ties that generically named record to Reserve. ABC Labs' headquarters, the reported Cayman Reserve Rights Foundation, and founders' current roles are not established by official or legal-self sources.

SaucerSwap SAUCE

Decided 2026-09-14 · due 2026-10-14

SaucerSwap Labs, Inc. is a Delaware corporation (legal terms) giving a notices address of 63 Federal Street, Unit #349, Portland, ME; SAUCE is minted by protocol contracts with no offshore foundation found. Listing still needs T2 or T3 evidence (US status of co-founders Peter Campbell and Joseph Bergvinson, or US operations) and confirmation that the Portland address is a physical office rather than a mail drop.

Sei SEI

Decided 2026-09-14 · due 2026-10-14

A 21Shares S-1/A identifies Sei Labs, Inc. as the core development organization behind the Sei Network, co-founded by Jeffrey Feng and Jay Jog, and its privacy policy and Texas record give a physical address at 1201 Wilson Blvd, Floor 25, Arlington, VA. Sei Labs' state of incorporation is not established (its terms give only Delaware governing law), the Sei Foundation's jurisdiction is unknown, and founders' US status is not established.

Siacoin SC

Decided 2026-09-14 · due 2026-10-14

Sia Foundation Inc is a US 501(c)(3) in Randolph, Massachusetts, and pays Sia's core developers, including co-founder Luke Champine, so it is plausibly a US direct listing. Its only address on file is 75 N Main St 6016, a numbered unit consistent with a mail service, and its state of incorporation is not evidenced; its terms choose Massachusetts law, which is not incorporation evidence. Needs an incorporation record and a physical headquarters.

SKALE SKL

Decided 2026-09-14 · due 2026-10-14

The SKALE site carries a copyright notice for N.O.D.E. Anstalt (jurisdiction not verified), and governance runs through the SKALE DAO. SKALE's docs name SKALE Labs as a developer, but skalelabs.com did not respond and no source gives its entity, jurisdiction, or headquarters. Confirm N.O.D.E. Anstalt's jurisdiction and role, and whether a US SKALE Labs entity is still the principal contributor.

Stronghold SHX

Decided 2026-09-14 · due 2026-10-14

SHx is issued by Stronghold Anchor Limited, a New Zealand company, so listing needs the foundation carve-out with a US principal contributor. Stronghold's payment services are provided by Stronghold Institutional Services LLC under California-law terms, but that LLC's state of formation, physical headquarters and role in building SHx are not yet documented.

Telcoin TEL

Decided 2026-09-14 · due 2026-10-14

Telcoin's parent is unresolved: the terms name Telcoin Holdings Inc., but telco.in's copyright line is Telcoin Holdings Pte. Ltd. (Singapore). The group lists subsidiaries in over a dozen countries, and the Telcoin Association is a Swiss association seated in Lugano. US entities (Telcoin LLC in Los Angeles; Telcoin Inc and the Nebraska-chartered Telcoin Digital Asset Bank in Norfolk, NE) are subsidiaries, and no US principal contributor for the TEL network is documented. Leaning not-eligible unless the parent proves to be a US corporation headquartered in the US.

Tellor Tributes TRB

Decided 2026-09-14 · due 2026-10-14

Tellor's site names a founding team (Brenda Loya, CEO; Nick Fett, CTO), but tellor.io, its docs, and the Tellor hub give no legal entity, jurisdiction, or address, and TRB is minted by the protocol as reporter and validator rewards. Identify the operating entity behind Tellor, if any, and its registration and headquarters; if there is no operating entity, Tellor is not-eligible.

Theta Fuel TFUEL

Decided 2026-09-14 · due 2026-10-14

TFUEL is the operational token of Theta Network, built by Theta Labs, Inc., a Delaware corporation that sold SAFTs under a 2018 Form D/A. The Theta Network (THETA) record, suspended on 2026-09-14, meets Tests 1 and 4 but lacks sourced Test 2 or Test 3 evidence. TFUEL shares that entity and that gap.

tx TX

Decided 2026-09-14 · due 2026-10-14

tx (formed by merging Coreum and Sologenic) is operated by TX Labs, LC, a Wyoming LLC per its legal terms, and CoinGecko describes it as US-headquartered, but no headquarters address, Wyoming registry record, token-issuer or foundation entity, or founder evidence was found.

UMA UMA

Decided 2026-09-14 · due 2026-10-14

The UMA interfaces are provided by Risk Labs, which EDGAR records as a Cayman Islands exempted company (Form D, 2018), and Risk Labs Foundation calls itself the team behind UMA. That Form D gives a New York principal address (259 Bowery) for Risk Labs and its directors Hart Lambur and Xuelin Lu, and the Delaware affiliate Risk Labs USA, Inc. uses Xuelin Lu at the same address as its New York process agent. Confirm that Risk Labs USA, Inc. employs the team and is the principal contributor, and its current headquarters.

Venice Token VVV

Decided 2026-09-14 · due 2026-10-14

Venice.ai, Inc. is a Wyoming corporation (2026 Form D) with Erik Voorhees and Jesse Proudman as executive officers and directors and Haseeb Qureshi as a director. Its only address in the Form D and its terms is 1309 Coffeen Ave, Ste 14343, Sheridan, WY, a registered-agent suite rather than a physical headquarters, and no source names the entity that issues VVV.

Verona VERONA

Decided 2026-09-14 · due 2026-10-14

Verona (formerly XION, same project as coingeckoId xion-2) is developed by Burnt Labs. The legal pages found name only the Inferno Research Foundation as operator (with Cayman Islands governing law, which is not incorporation evidence), and Burnt Labs, the developer, has no jurisdiction or headquarters stated in any document found; no US entity is established, but a US Burnt Labs acting as principal contributor has not been ruled out.

Wormhole W

Decided 2026-09-14 · due 2026-10-14

The wormhole.com sites are operated by Wormhole Foundation, registered in George Town, Cayman Islands, so only the foundation carve-out could apply. The candidate US contributor, Wormhole Labs, gives no legal entity, jurisdiction, or address on its own site, so its principal-contributor status, registration, and headquarters are unestablished. Identify the Wormhole Labs legal entity and confirm US registration and headquarters.

Xion XION

Decided 2026-09-14 · due 2026-10-14

XION (rebranded Verona, same project as coingeckoId verona) is developed by Burnt Labs. The legal pages found name only the Inferno Research Foundation as operator (with Cayman Islands governing law, which is not incorporation evidence), and Burnt Labs, the developer, has no jurisdiction or headquarters stated in any document found; no US entity is established, but a US Burnt Labs acting as principal contributor has not been ruled out.

Ycash YEC

Decided 2026-09-14 · due 2026-10-14

Ycash is a Zcash-fork proof-of-work chain supported by the Ycash Foundation, which its site says is a Delaware nonprofit; founder Howard Loo is a California State Bar member. The only registry address found is a P.O. box in Los Altos, CA, which cannot carry T1, and ProPublica notes the foundation is not on the IRS's latest exempt list. As a 100% volunteer organization it may have no physical HQ (editor call).

Zcash ZEC

Decided 2026-09-14 · due 2026-10-14

Protocol-native token with no offshore foundation; the Zcash Foundation is a Delaware nonprofit in McLean, Virginia, but Grayscale's S-3/A identifies ZODL (Znewco, Inc.) as the entity continuing core Zcash software and protocol development after the ECC team left in January 2026, so ZODL is the principal contributor. Znewco, Inc. was chartered in Texas on December 29, 2025, and its only address in the Texas record and its privacy policy is a Dallas PMB, so no physical headquarters is established and US operations under this structure are under 12 months old.

Zebec Network ZBCN

Decided 2026-09-14 · due 2026-10-14

Zebec lists San Francisco, London and New York team locations and owns US payroll company PayBridge, but its terms name only "Zebec and its affiliated entities" and no document found identifies the ZBCN issuer, a foundation, or any operating entity with a jurisdiction or headquarters.

ZetaChain ZETA

Decided 2026-09-14 · due 2026-10-14

ZetaChain's MiCAR white paper names Meta Protocol, Inc. as the issuer of ZETA and the only entity implementing the project, with legal form XTIQ (a Delaware corporation), a Delaware registered address, and a head office at 415 Mission St, San Francisco; its terms of use give only a PMB notice address. Tests 1 and 4 look supportable, but no source establishes US founders with current roles or US primary operations (engineering majority, governance entity, or US regulatory engagement). Name the founders and establish where the engineering team works.

Aave AAVE

Decided 2026-04-29

• Test 1 · HQ
• Test 4 · entity

Avara, the principal developer, is based in London; no US carve-out applies. Decision carried from the v0.1 allowlist review; source documents to be attached at the next review.

Adventure Gold AGLD

Decided 2026-09-14

• Test 1 · HQ
• Test 4 · entity
• Structure

AGLD is mapped to the Loot project (lootproject.com), whose FAQ describes Loot as having no company or team. No legal entity or named team responsible for the token was identified.

Aerodrome Finance AERO

Decided 2026-09-14

• Test 1 · HQ
• Test 2 · founders
• Test 3 · operations
• Test 4 · entity
• Structure

The token issuer is Aerodrome Foundation, a Cayman Islands foundation company, and the principal contributor Dromos Labs has no established jurisdiction, HQ, or US filings; the team is partly non-public. With no US operating entity shown, the foundation carve-out cannot apply.

Ava AI AVA

Decided 2026-09-14

• Test 1 · HQ
• Test 4 · entity
• Structure

AVA is a community-launched Solana memecoin (pump.fun) tied to Holoworld's AI agent character. No named US company or LLC has taken responsibility for the token, and Holoworld's legal pages returned 404, so no US entity was identified.

Axelar AXL

Decided 2026-09-14

• Test 1 · HQ
• Test 2 · founders
• Test 3 · operations
• Test 4 · entity
• Structure

Axelar Foundation is a Cayman Islands foundation company. Its initial developer, Interop Labs Inc., agreed in December 2025 for its team and IP to join Circle (Circle's 10-Q records the technology purchase in January 2026), and Common Prefix, whose team works from European cities, now leads development. No US principal contributor remains, so the foundation carve-out cannot apply.

Baby Doge Coin BABYDOGE

Decided 2026-09-14

• Test 1 · HQ
• Test 4 · entity
• Structure

The Baby Doge terms (linked from babydoge.com) state the website is owned and operated by ZENITHSOFT LABS PTE. LTD. (Co. Reg. No. 202438375R), a Singapore private-company designation. No US entity or named US team responsible for the token was identified.

Bertram The Pomeranian BERT

Decided 2026-09-14

• Test 1 · HQ
• Test 4 · entity
• Structure

The bert.global terms (updated 18 June 2026) name The Legacy of Bert Foundation as the entity responsible for the $BERT brand and select Cayman Islands law and courts. No US entity or named US team responsible for the token was identified.

Bitcoin Cash BCH

Decided 2026-09-14

• Test 1 · HQ
• Test 4 · entity
• Structure

Bitcoin Cash is a leaderless proof-of-work fork of Bitcoin (August 2017) maintained by independent node teams. No operating entity or US principal contributor exists to carry Tests 1 and 4.

Blur BLUR

Decided 2026-09-14

• Test 1 · HQ
• Test 4 · entity
• Structure

The Blur marketplace terms, linked from blur.io, say the site is offered by Non Fungible Trading Ltd., with a notice address in Road Town, Tortola, British Virgin Islands. The Blur Foundation, which supports the Blur protocol, uses Panama law in its site terms. No US operating company or principal contributor is named.

Bonk BONK

Decided 2026-09-14

• Test 1 · HQ
• Test 4 · entity
• Structure

The bonkcoin.com disclaimers name BONK Community Foundation, Ltd. as site operator without stating a US jurisdiction or address, and an SEC-filed fund prospectus describes BONK as launched by a collective of Solana developers and community members. No named US team or LLC responsible for the token was identified; the site describes BNKK as an independent Nasdaq-listed company.

Casper Network CSPR

Decided 2026-09-14

• Test 1 · HQ
• Test 4 · entity
• Structure

Casper Network is stewarded by the Casper Association in Zug, Switzerland, and its original developer Casper Labs now operates as Prove AI AG, a Swiss corporation also registered in Zug. No US entity is identified as principal contributor.

ConstitutionDAO PEOPLE

Decided 2026-09-14

• Test 1 · HQ
• Test 4 · entity
• Structure

ConstitutionDAO was a 2021 single-purpose crowdfunding DAO; its site states the core team chose to wind down, that PEOPLE tokens carry no rights, governance, or utility beyond redemption, and that it will not endorse future plans for the token. There is no operating entity or named team responsible for the token.

Cosmos Hub ATOM

Decided 2026-04-29

• Test 1 · HQ
• Test 4 · entity
• Structure

The Interchain Foundation is Swiss and the former Tendermint Inc. successor restructured offshore. Decision carried from the v0.1 allowlist review; source documents to be attached at the next review.

Curve DAO CRV

Decided 2026-04-29

• Test 1 · HQ
• Test 2 · founders
• Test 4 · entity

Curve Finance is Switzerland-based and founder Michael Egorov is not a US person. Decision carried from the v0.1 allowlist review; source documents to be attached at the next review.

DAI on PulseChain DAI

Decided 2026-09-14

• Test 1 · HQ
• Test 4 · entity
• Structure

The listed PulseChain contract (0x6B175474E89094C44Da98b954EedeAC495271d0F) shares the address of Ethereum-mainnet DAI, and PulseChain's explorer reports it as "Dai Stablecoin" with a total supply of about 44.4 billion; the PulseChain site separately lists bridged "DAI from Ethereum". No custodian holding reserves for this copy and no issuer responsible for it was identified, so the wrapper pathway has no qualifying subject entity.

Decred DCR

Decided 2026-09-14

• Test 1 · HQ
• Test 4 · entity
• Structure

Decred is run by stakeholders and paid for from its on-chain treasury. More than 50 independent and corporate contractors (among them Company 0, Raedah Group, and Eeter) invoice Decred Holdings Group LLC, and no single operating entity is its principal contributor.

DigiByte DGB

Decided 2026-09-14

• Test 1 · HQ
• Test 4 · entity
• Structure

DigiByte is a community-maintained proof-of-work UTXO chain (DigiByte-Core on GitHub). Its official site names no operating company or foundation, and no US entity is shown to be its principal contributor.

Dogecoin DOGE

Decided 2026-09-14

• Test 1 · HQ
• Test 4 · entity
• Structure

Dogecoin is an open-source proof-of-work chain developed by volunteers, with no operating company as principal contributor. House of Doge Inc. (Miami) is the Dogecoin Foundation's commercial arm providing marketing and licensing services, not protocol development, and no entity is shown to maintain Dogecoin Core.

Fantom FTM

Decided 2026-04-29

• Test 1 · HQ
• Test 2 · founders
• Test 4 · entity
• Structure

Predecessor of Sonic: Cayman foundation; founder Andre Cronje is South African. Decision carried from the v0.1 allowlist review; source documents to be attached at the next review.

First Digital USD FDUSD

Decided 2026-09-14

• Test 1 · HQ
• Test 3 · operations
• Test 4 · entity

Issuer domicile decides for stablecoins. FDUSD is issued by First Digital Trust, a trust company registered under Hong Kong's Trust Ordinance, run by the Hong Kong-based First Digital group. No US issuer or operating entity was found. The issuer's own site (firstdigitallabs.com) blocked retrieval, so this rests on aggregator sources.

Flux FLUX

Decided 2026-09-14

• Test 1 · HQ
• Test 4 · entity

Flux is operated by InFlux Technologies Limited (formerly Zel Technologies Limited), an English private limited company registered in Cheltenham, England. It has a US-resident American director, but no US-registered operating company or principal contributor was identified.

Global Dollar USDG

Decided 2026-09-14

• Test 1 · HQ
• Test 3 · operations
• Test 4 · entity

Issuer domicile decides for stablecoins. USDG is issued by Paxos Digital Singapore Pte. Ltd. (Singapore, supervised by MAS) and by Paxos Issuance Europe (Finland, FIN-FSA/MiCA); no US Paxos entity issues USDG. The US parent group does not qualify a foreign-issued stablecoin.

Internet Computer ICP

Decided 2026-04-29

• Test 1 · HQ
• Test 4 · entity
• Structure

The DFINITY Foundation is Swiss. Decision carried from the v0.1 allowlist review; source documents to be attached at the next review.

IoTeX IOTX

Decided 2026-09-14

• Test 1 · HQ
• Test 4 · entity

IoTeX's terms and privacy notice (updated June 1, 2025) name IoTeX Technology, a company registered in Tortola, British Virgin Islands, as the operator of iotex.io. No US operating company or US principal contributor was identified.

Jupiter JUP

Decided 2026-09-14

• Test 1 · HQ
• Test 4 · entity
• Structure

Jupiter's terms say the jup.ag interface and the Jupiter protocol are made available and deployed by Block Raccoon S.A., and deem the interface based solely in Panama. Jupiter refuses wallets located in the United States. No US operating company or principal contributor is named.

Kaspa KAS

Decided 2026-09-14

• Test 1 · HQ
• Test 4 · entity
• Structure

Kaspa is a fair-launch proof-of-work chain with no premine, no issuing entity, and no operating company. No US entity is recorded as its principal contributor.

Koma Inu KOMA

Decided 2026-09-14

• Test 1 · HQ
• Test 4 · entity
• Structure

The komabnb.com site describes a community-driven BNB Chain memecoin backed by an unnamed team and names no legal entity, jurisdiction, or individual. Anonymous memecoins are not eligible.

Kusama KSM

Decided 2026-09-14

• Test 1 · HQ
• Test 4 · entity
• Structure

Kusama is Polkadot's canary network, stewarded by the Web 3.0 Technologies Foundation (Zug, Switzerland), whose privacy policy is served on kusama.network, and built principally by Parity Technologies Limited (London, England). No US entity is involved; consistent with the Polkadot not-eligible decision.

Lido DAO LDO

Decided 2026-04-29

• Test 1 · HQ
• Test 4 · entity
• Structure

Cayman foundation with no substantive US principal contributor. Decision carried from the v0.1 allowlist review; source documents to be attached at the next review.

Lumia LUMIA

Decided 2026-09-14

• Test 1 · HQ
• Test 4 · entity
• Structure

Lumia (the rebranded Orion Protocol, ORN swapped 1:1 to LUMIA) gives a George Town, Grand Cayman address in its site footer and labels Dubai as its HQ; no US legal entity is identified (the site lists a New York 'institutional hub' but names no US company).

Maker MKR

Decided 2026-04-29

• Test 1 · HQ
• Test 2 · founders
• Test 4 · entity

Predecessor of Sky: founder Rune Christensen is Danish and principal contributors are distributed; no US operating company. Decision carried from the v0.1 allowlist review; source documents to be attached at the next review.

Mantle MNT

Decided 2026-04-29

• Test 1 · HQ
• Test 4 · entity
• Structure

Governed through BitDAO structures in the Cayman Islands. Decision carried from the v0.1 allowlist review; source documents to be attached at the next review.

Movement MOVE

Decided 2026-09-14

• Test 1 · HQ
• Test 2 · founders
• Test 3 · operations
• Test 4 · entity
• Structure

Bankruptcy filings state MOVE is minted by Movement Limited (BVI) under Movement Network Foundation (Cayman), and the US developer MVMT Labs, Inc. (Delaware) filed Chapter 11 on 2026-07-15 with no full-time employees after its team and IP moved to the foundation side and Move Industries in late 2025. No US principal contributor or founder in an operational role remains.

Osmosis OSMO

Decided 2026-09-14

• Test 1 · HQ
• Test 4 · entity
• Structure

The Osmosis front end's legal disclaimer names Osmosis Labs Pte. Ltd. (a Singapore-style private limited company) as the developer of the initial protocol code and Osmosis Foundation Ltd. as the foundation; no US entity is named in the project's legal documents.

Pendle PENDLE

Decided 2026-04-29

• Test 1 · HQ
• Test 4 · entity

Singapore-based development. Decision carried from the v0.1 allowlist review; source documents to be attached at the next review.

PepeCoin PEPECOIN

Decided 2026-09-14

• Test 1 · HQ
• Test 4 · entity
• Structure

The project site's only entity reference is a stylized "Pepecoin Corporation" copyright line in a mock BIOS screen, with no jurisdiction, address, or legal terms; the name was not found in EDGAR or the NY, CO, OR, or TX registries. No named US team or legal entity responsible for the token was identified.

POL (ex-MATIC) POL

Decided 2026-04-29

• Test 2 · founders
• Test 3 · operations

Polygon Labs has a US presence, but the founding team and the majority of engineering are India-based. Decision carried from the v0.1 allowlist review; source documents to be attached at the next review.

Polkadot DOT

Decided 2026-04-29

• Test 1 · HQ
• Test 4 · entity
• Structure

Web3 Foundation is Swiss and Parity Technologies is UK-based; no US principal contributor. Decision carried from the v0.1 allowlist review; source documents to be attached at the next review.

Puffer PUFFER

Decided 2026-09-14

• Test 1 · HQ
• Test 4 · entity
• Structure

Puffer services and its website are provided by Puffer Foundation, a Cayman Islands foundation company; the foundation carve-out would require a US principal contributor, and none is identified in the project documents.

Ravencoin RVN

Decided 2026-09-14

• Test 1 · HQ
• Test 4 · entity
• Structure

Ravencoin is volunteer-run open-source software. The Ravencoin Foundation, a US non-profit, says it is not Ravencoin and only holds and distributes development funds, so no entity is the principal contributor.

Realio Network Token RIO

Decided 2026-09-14

• Test 4 · entity
• Structure

Realio Network LTD is incorporated in the British Virgin Islands (EDGAR), and the Realio sites are owned by Realio Technology LTD. Both use New York addresses, but no US-registered entity is identified as the network's principal contributor, which a non-US network entity requires.

Renzo REZ

Decided 2026-09-14

• Test 1 · HQ
• Test 4 · entity
• Structure

Renzo Finance services are provided by RestakeX Ventures Ltd., established in and with its principal place of business in Panama City, Panama, which owns the Renzo Finance name and IP and excludes US persons. The homepage footer also names a "Renzo Finance, Inc." whose jurisdiction and role were not found.

Sky SKY

Decided 2026-04-29

• Test 1 · HQ
• Test 2 · founders
• Test 4 · entity

Founder Rune Christensen is Danish and principal contributors are distributed; no US operating company. Decision carried from the v0.1 allowlist review; source documents to be attached at the next review.

Sonic S

Decided 2026-04-29

• Test 1 · HQ
• Test 2 · founders
• Test 4 · entity
• Structure

Cayman foundation; founder Andre Cronje is South African. Decision carried from the v0.1 allowlist review; source documents to be attached at the next review.

SuperVerse SUPER

Decided 2026-09-14

• Test 1 · HQ
• Test 4 · entity
• Structure

The superverse.co terms state the project is owned and operated by SuperFarm Foundation, give a notice address in Panama City, Panama, and select Panama law. No US principal contributor is named by the project, so the foundation carve-out is not met.

Synthetix SNX

Decided 2026-04-29

• Test 1 · HQ
• Test 4 · entity

Australia-based development with no US carve-out. Decision carried from the v0.1 allowlist review; source documents to be attached at the next review.

Tezos XTZ

Decided 2026-04-29

• Test 1 · HQ
• Test 4 · entity
• Structure

The Tezos Foundation is Swiss; the original US company, Dynamic Ledger Solutions, wound down. Decision carried from the v0.1 allowlist review; source documents to be attached at the next review.

Vaulta A

Decided 2026-09-14

• Test 1 · HQ
• Test 4 · entity
• Structure

Vaulta (rebranded EOS) is stewarded by the Vaulta Foundation, formerly the EOS Network Foundation, which states it is headquartered in Canada and operates from Calgary, Alberta. No US entity is identified.

Verge XVG

Decided 2026-09-14

• Test 1 · HQ
• Test 4 · entity
• Structure

Verge is a community proof-of-work privacy coin created in 2014 under a pseudonymous founder ("Justin Sunerok"). Its site and repository disclose no legal entity, and no named US team or company has taken responsibility for it.