This page was compiled by Blockworks using publicly available information reviewed consistent with the TTF, possibly together with information supplied directly by the project where provided. Project-supplied information may correct, update, or supplement the public record, and may not be independently verifiable; Blockworks presents it as provided and does not verify or warrant its accuracy. Because this page depends on what has been disclosed, it may be incomplete — certain categories are more likely to include undisclosed items (e.g., non-announced fundraisings or material relationships), and the absence of an entry should not be read as confirmation that none exists.
Provide a concise narrative that clearly states each of (a)–(e) below.
Response
Consumers and businesses that want to move between fiat money and crypto face fragmented payment rails, local licensing rules and settlement friction. Alchemy Pay is a payment solutions provider that builds infrastructure to bridge fiat and crypto economies, offering payment gateways and on and off ramp services so that businesses and consumers can transact in both traditional currencies and cryptocurrencies. The MiCA white paper states that the project was founded in 2017, and Alchemy Pay reports fiat payment coverage in 173 countries.
(Source: Alchemy Pay MiCA White Paper (OKX), Alchemy Pay Michigan Money Transmitter License)
Alchemy Pay draws on a committee-managed treasury that holds team and ecosystem reward tokens for market expansion, operational growth, partner rebates and community airdrop campaigns. Its stated priorities are expanding regulated payment coverage, including money transmitter licenses in 19 U.S. states, and building Alchemy Chain, a Layer-1 for stablecoin and cross-border payments whose mainnet went live in May 2026. The February 2026 supply framework directs newly issued ACH to validator and node incentives, payment activity, developers and merchant, stablecoin and infrastructure integrations.
(Source: Alchemy Pay MiCA White Paper (OKX), Alchemy Pay Michigan Money Transmitter License, The Alchemy Chain Mainnet Is Live, ACH Supply Framework (Cryptowisser))
Alchemy Pay runs a hybrid crypto-fiat payment gateway. Merchants accept a range of cryptocurrencies and are settled in local fiat currency, and integrators use SDKs and APIs to embed the gateway and the on and off ramp in online and offline retail systems. Alchemy Chain extends this stack as a payments-focused Layer-1 that uses ACH as its gas token, and Alchemy Pay describes the chain as aligned with MiCA, PSD2 and the Hong Kong stablecoin framework.
(Source: Alchemy Pay MiCA White Paper (OKX), The Alchemy Chain Mainnet Is Live, Alchemy Chain Roadmap)
ACH is a utility token issued as an ERC-20 on Ethereum and a BEP-20 on BNB Smart Chain. Enterprise partners such as merchants and payment platforms pledge ACH to integrate the gateway, with the pledge tied to expected transaction volume and reclaimable when the partner leaves. ACH is the native gas token of Alchemy Chain and supports validator participation. The MiCA white paper describes governance voting as a planned future use and states that ACH confers no claim to profits, dividends or issuer assets.
The project has run under a management committee since January 2023, and that committee controls the treasury and decides changes to token rights. Onchain, the ACH minter role sits with a 3-of-6 Safe multisig whose signers are not publicly named, and a single externally owned address holds the pauser role. The MiCA white paper plans a formal onchain governance mechanism for ACH holders with no timeline. A community vote on the supply adjustment schedule ran from May 12 to May 17, 2026, and its mechanism and result are not published.
(Source: Alchemy Pay MiCA White Paper (OKX), Blockscout, Minter Safe, Blockscout, ACH Token, ACH Supply Adjustment Vote (TradingView))
For each existing entity: Labs/DevCo (e.g., Founder, CEO, CTO, COO), Foundation (e.g., President, Executive Director, CFO, COO), and DAO / onchain governance leadership (if applicable) list the: (a) full names, (b) official titles, (c) and prior experience of key team members. For any non-existent entity, explicitly mention it does not exist. External links may be included but they will not factor into the score.
Response
Full Name | Entity | Official Title | Prior Experience |
|---|---|---|---|
John Tan | Labs/DevCo | Co-Founder in the MiCA white paper list of persons involved, and CEO of Alchemy Pay since July 2021 (Alchemy Pay MiCA White Paper (OKX), Alchemy Pay COO John Tan Succeeds Molly Zheng as CEO) | Joined Alchemy Pay in business development and then served as COO, where he led partnerships with Shopify, Binance and Huobi before his promotion to CEO (Alchemy Pay COO John Tan Succeeds Molly Zheng as CEO). |
Molly Zheng | Labs/DevCo | Listed as COO with a U.S. business address in the MiCA white paper, and named Chairwoman when she handed the CEO role to John Tan in July 2021 (Alchemy Pay MiCA White Paper (OKX), Alchemy Pay COO John Tan Succeeds Molly Zheng as CEO) | More than 20 years in payments, including Senior Consultant at PayPal China, SVP at HSBC China, Director at GE Money and Chief Representative of MasterCard China (Alchemy Pay COO John Tan Succeeds Molly Zheng as CEO). |
Shawn Shi | Labs/DevCo | Co-Founder, based in Singapore (Alchemy Pay MiCA White Paper (OKX)), also described as Founder (Alchemy Pay, Bridging Global Economies (Yahoo Finance)) | Named a 2022 Forbes China Web 3.0 Innovation Pioneer, and the sources reviewed disclose no earlier roles (Alchemy Pay, Bridging Global Economies (Yahoo Finance)). |
Gibbs Lvy | Labs/DevCo | Co-Founder (Alchemy Pay MiCA White Paper (OKX)) | The MiCA white paper lists no business address for him, and the sources reviewed disclose no prior experience (Alchemy Pay MiCA White Paper (OKX)). |
Jonas Černius | Labs/DevCo | Head of Compliance, based in Vilnius, Lithuania (Alchemy Pay MiCA White Paper (OKX), Alchemy Pay, Bridging Global Economies (Yahoo Finance)) | More than 10 years in civil service and in finance compliance and legal operations (Alchemy Pay, Bridging Global Economies (Yahoo Finance)). |
Arda Senoz | Labs/DevCo | Head of the Alchemy Pay ecosystem, the title he held at an April 19, 2026 Hong Kong industry forum, the most recent source found (ChainCatcher, Alchemy Pay at Hong Kong Web3 Forum) | The sources reviewed disclose no prior roles before Alchemy Pay (ChainCatcher, Alchemy Pay at Hong Kong Web3 Forum). |
No primary foundation exists for Alchemy Pay or ACH. The MiCA white paper names Alchemy GPS Europe UAB as issuer and Alchemy GPS Singapore PTE. LTD. as its parent and identifies no foundation (Alchemy Pay MiCA White Paper (OKX)). A Singapore exempt private company named Alchemy Pay Foundation Pte. Ltd. (UEN 202133556W, registered as a holding company) is live in the Singapore register, but no source ties it to issuing ACH at launch or gives it any role over ACH (OpenCorporates, Alchemy Pay Foundation Pte. Ltd., fetched 2026-10-06). | Foundation | No primary foundation officers exist because no primary foundation exists, and the officers of Alchemy Pay Foundation Pte. Ltd. are not published in the sources reviewed (Alchemy Pay MiCA White Paper (OKX)). | No foundation officers exist, so there is no prior experience to report. |
No DAO or active onchain governance exists for ACH. The project has been run by a management committee since January 2023, and onchain governance is planned with no timeline (Alchemy Pay MiCA White Paper (OKX)). | DAO/Onchain Governance | The management committee members are not named, and the 3-of-6 Safe that holds the ACH minter role has signers who are not publicly identified (Alchemy Pay MiCA White Paper (OKX), Blockscout, Minter Safe). | No DAO officeholders are named, so there is no prior experience to report. |
Provide a structured description of the DAO's governance, powers, and economic rights. If a DAO does not exist, state so. Address the lettered items below. Even if there is no DAO, there must be an answer to (d).
Response
No DAO exists for ACH, so no DAO owns or controls IP. The MiCA white paper describes a management committee that has overseen business operations since January 2023 and plans onchain governance with no timeline, and it assigns no codebase, trademark or brand to a DAO.
(Source: Alchemy Pay MiCA White Paper (OKX))
No DAO exists, so no DAO holds contract or administrative powers. The ACH contract on Ethereum grants minting to a 3-of-6 Safe multisig and pausing to a single externally owned address, and neither is a governance executor controlled by tokenholder votes.
(Source: Alchemy Pay MiCA White Paper (OKX), Blockscout, ACH Token, Blockscout, Minter Safe)
No DAO exists, and no locking or staking mechanism grants governance rights. Enterprise partners pledge ACH to access the payment gateway, and this pledge gives service access only, with no voting or decision rights.
(Source: Alchemy Pay MiCA White Paper (OKX))
ACH holders have no rights over revenue distribution or the treasury. The MiCA white paper states that the token confers no claim to profits, dividends or issuer assets, that no supply adjustment or value protection scheme exists and that treasury control remains with the management committee. A community vote on the supply adjustment schedule ran from May 12 to May 17, 2026, but its voting mechanism, binding effect and result are not published.
(Source: Alchemy Pay MiCA White Paper (OKX), ACH Supply Adjustment Vote (TradingView))
No DAO exists, so there is no DAO to dissolve and no dissolution mechanism. The MiCA white paper, the supply framework announcement and the mainnet release describe no DAO legal wrapper or wind-down vote.
(Source: Alchemy Pay MiCA White Paper (OKX), ACH Supply Framework (Cryptowisser), The Alchemy Chain Mainnet Is Live)
For the Primary Foundation do the following independently. If an entity does not exist, state that explicitly. Items (a)–(f) apply only if that entity exists; state explicitly that the entity doesn't exist. Definitions: The primary Foundation and DevCo can be explained as those entities which are directly involved in the issuance of the native token at launch.
Response
No primary foundation exists for Alchemy Pay or ACH. The MiCA white paper names Alchemy GPS Europe UAB as issuer and Alchemy GPS Singapore PTE. LTD. as its parent, and identifies no foundation, so there is no foundation entity type or jurisdiction to report. A Singapore exempt private company limited by shares named Alchemy Pay Foundation Pte. Ltd. (UEN 202133556W, registered at 60 Paya Lebar Road with holding-company activity codes) is live, but no source ties it to issuing ACH at launch or gives it any role over ACH, so it is not treated as the primary foundation (OpenCorporates, Alchemy Pay Foundation Pte. Ltd., fetched 2026-10-06).
(Source: Alchemy Pay MiCA White Paper (OKX))
No primary foundation exists for Alchemy Pay or ACH. The MiCA white paper names Alchemy GPS Europe UAB as issuer and Alchemy GPS Singapore PTE. LTD. as its parent, and identifies no foundation, so no foundation owns IP or holds subsidiaries.
(Source: Alchemy Pay MiCA White Paper (OKX))
No primary foundation exists for Alchemy Pay or ACH. The MiCA white paper names Alchemy GPS Europe UAB as issuer and Alchemy GPS Singapore PTE. LTD. as its parent, and identifies no foundation, so no foundation holds powers over governance, the treasury, protocol resources or token administration.
(Source: Alchemy Pay MiCA White Paper (OKX))
No primary foundation exists for Alchemy Pay or ACH. The MiCA white paper names Alchemy GPS Europe UAB as issuer and Alchemy GPS Singapore PTE. LTD. as its parent, and identifies no foundation, so no foundation can influence the DevCo.
(Source: Alchemy Pay MiCA White Paper (OKX))
No primary foundation exists for Alchemy Pay or ACH. The MiCA white paper names Alchemy GPS Europe UAB as issuer and Alchemy GPS Singapore PTE. LTD. as its parent, and identifies no foundation, so no foundation holds pause, upgrade or executor authority over the ACH contracts.
(Source: Alchemy Pay MiCA White Paper (OKX), Blockscout, ACH Token)
No primary foundation exists for Alchemy Pay or ACH. The MiCA white paper names Alchemy GPS Europe UAB as issuer and Alchemy GPS Singapore PTE. LTD. as its parent, and identifies no foundation, so no mechanism directs treasury assets, fees, revenue or tokens to a foundation.
(Source: Alchemy Pay MiCA White Paper (OKX))
For the Primary DevCo do the following independently. If an entity does not exist, state that explicitly. Items (a)–(f) apply only if that entity exists; state explicitly that the entity doesn't exist. Definitions: The primary Foundation and DevCo can be explained as those entities which are directly involved in the issuance of the native token at launch.
Response
Alchemy GPS Europe UAB is a Lithuanian private limited liability company, registration number 305972625, registered on January 6, 2022 at J. Basanavičiaus g. 26, Vilnius. It is the issuer named in the MiCA white paper and develops cloud-based payment processing software that supports the Alchemy Pay platform. Its parent is Alchemy GPS Singapore PTE. LTD., a Singapore company that provides IT consultancy, domestic money transfer, merchant acquisition and digital payment token services. Alchemy Pay describes itself as Singapore-based.
(Source: Alchemy Pay MiCA White Paper (OKX), Alchemy Pay COO John Tan Succeeds Molly Zheng as CEO)
The MiCA white paper does not state which group entity owns the Alchemy Pay code, trademarks or brand, and no IP license is published. The group holds money transmitter licenses in 19 U.S. states, an Australian digital currency exchange registration, a South Korean electronic financial business registration and admission to the Swiss self-regulatory organisation VQF, and it has invested in SFC-licensed HTF Securities in Hong Kong. The U.S. money transmitter licenses are held by Alchemy Pay Inc. (NMLS ID 2449570) (Alchemy Pay Secures Money Services License in Iowa, 2023-11-23). The legal names of the entities holding the non-U.S. registrations are not disclosed in the sources reviewed.
(Source: Alchemy Pay MiCA White Paper (OKX), Alchemy Pay Michigan Money Transmitter License)
No DAO exists. The management committee controls the treasury, which holds team and ecosystem reward tokens, and decides changes to token rights. The project also controls a rewards pool address. ACH minting sits with a 3-of-6 Safe multisig, which on April 9, 2026 minted 5,346,246,088 ACH into five revocable TokenVesting contracts. Those vesting contracts are owned by a single externally owned address that can revoke unvested tokens. Alchemy Pay has not publicly named the Safe signers or the vesting owner, so the link between these addresses and the committee is not documented.
(Source: Alchemy Pay MiCA White Paper (OKX), Blockscout, Minter Safe, Etherscan, April 9 2026 Mint Transaction, Blockscout, TokenVesting 0xEae8, Blockscout, TokenVesting 0x7D56, Blockscout, TokenVesting 0xF72E, Blockscout, TokenVesting 0x1918, Blockscout, TokenVesting 0x174E)
No primary foundation exists, so the DevCo has no foundation to influence. No source describes any power of the DevCo over Alchemy Pay Foundation Pte. Ltd. (OpenCorporates, Alchemy Pay Foundation Pte. Ltd.).
(Source: Alchemy Pay MiCA White Paper (OKX))
The Ethereum ACH contract is a non-upgradeable ERC-20 that is mintable, burnable and pausable, with no supply cap in code. The 3-of-6 Safe at 0x483a0Ad7bE1381Ca431216CA827aD38A96F0496f has held the minter role since January 2023 and is the only minter after the earlier minter renounced. The pauser role belongs to the externally owned address 0xb5b4f647d0632f49f19533824d4dfcc12ca0a5ff, granted in August 2021, and the contract is not paused as of 2026-10-05. The five TokenVesting contracts are revocable by their owner, the externally owned address 0x907acf93336f034df8198c39c6707507b516bc92.
(Source: Blockscout, ACH Token, Etherscan, ACH Token, Blockscout, Minter Safe, Etherscan, April 9 2026 Mint Transaction, Blockscout, TokenVesting 0xEae8)
No mechanism directs protocol fees or revenue to ACH holders or to the group's equityholders. The team received 18% of supply at launch, and the MiCA white paper states that this vesting has concluded. The committee may use treasury tokens for partner rebates and community airdrop campaigns. The 5,346,246,088 ACH minted in April 2026 vest to five externally owned beneficiary addresses that Alchemy Pay has not labelled, and the supply framework states that new ACH supports validators, nodes, payment activity, developers and integrations.
(Source: Alchemy Pay MiCA White Paper (OKX), ACH Supply Framework (Cryptowisser), Etherscan, April 9 2026 Mint Transaction, Blockscout, TokenVesting 0xEae8, Blockscout, TokenVesting 0x7D56, Blockscout, TokenVesting 0xF72E, Blockscout, TokenVesting 0x1918, Blockscout, TokenVesting 0x174E)
Disclose launch and initial supply details in a single initial allocation schedule covering the token's launch.
Response
The ACH contract minted an initial supply of 10,000,000,000 ACH, and the MiCA white paper dates the Ethereum deployment to September 4, 2019. ICO Drops records the token generation event as September 7, 2020. The amounts locked and unlocked at launch are not disclosed, and the MiCA white paper states only that the allocations carried vesting schedules, most of which have concluded.
(Source: Alchemy Pay MiCA White Paper (OKX), ICO Drops, Alchemy Pay, Etherscan, ACH Token)
ICO Drops lists a slightly different split, with 1,900,000,000 ACH across a 1,000,000,000 seed, an 800,000,000 private sale and a 100,000,000 IEO, and a 400,000,000 ecosystem bucket in place of the enterprise partner allocation.
(Source: Alchemy Pay MiCA White Paper (OKX), ICO Drops, Alchemy Pay)
No initial price per token is published. The MiCA white paper covers admission to trading only and states that no public offer was made, and ICO Drops lists a 100,000,000 ACH IEO with no price or date.
(Source: Alchemy Pay MiCA White Paper (OKX), ICO Drops, Alchemy Pay)
ACH.
(Source: Alchemy Pay MiCA White Paper (OKX), Etherscan, ACH Token)
ACH supply is not fixed. The MiCA white paper describes a fixed maximum supply of 10,000,000,000, but the token contract has no cap and lets the minter create new tokens. In February 2026, Alchemy Chain announced a supply framework that raises total supply to 10,800,000,000 in 2026, then grows supply at about 8% a year with about 15% annual disinflation, for a projected 15,346,246,088 ACH by 2037. On April 9, 2026, the minter Safe minted 5,346,246,088 ACH in one transaction, bringing onchain total supply to 15,346,246,088 ACH, the full 2037 projection, ahead of the May 12 to 17 community vote on the schedule. The new tokens sit in five TokenVesting contracts that release linearly over 10 years, and about 220.4 million ACH had been released as of 2026-10-06, of which about 4.9 million was returned to one vesting contract, leaving about 5.13 billion ACH in the contracts (onchain released() and balance reads of the five contracts). The BNB Smart Chain supply was not verified.
(Source: Alchemy Pay MiCA White Paper (OKX), ACH Supply Framework (Cryptowisser), ACH Supply Adjustment Vote (TradingView), Etherscan, April 9 2026 Mint Transaction, Blockscout, ACH Token, Blockscout, TokenVesting 0xEae8, Blockscout, TokenVesting 0x7D56, Blockscout, TokenVesting 0xF72E, Blockscout, TokenVesting 0x1918, Blockscout, TokenVesting 0x174E)
(Source: Alchemy Pay MiCA White Paper (OKX), ICO Drops, Alchemy Pay, Etherscan, April 9 2026 Mint Transaction, Blockscout, TokenVesting 0xEae8, Blockscout, TokenVesting 0x7D56, Blockscout, TokenVesting 0xF72E, Blockscout, TokenVesting 0x1918, Blockscout, TokenVesting 0x174E)
Address each of the following sub-items based on the project's airdrop status. If a sub-item does not apply to the project's situation, state that explicitly.
Response
Planned but not yet executed airdrop
Not applicable. ACH launched in 2020 and no TGE airdrop is planned.
(Source: Alchemy Pay MiCA White Paper (OKX), ICO Drops, Alchemy Pay)
Executed airdrop
The MiCA white paper states that the committee treasury funds community airdrop campaigns, and Alchemy Pay's monthly updates describe small promotional ACH rewards. Examples include a Telegram quiz for its 8th anniversary with 2,500 ACH, gaming events where five winners share 5,000 ACH and ACH rewards for visitors at TOKEN2049 Singapore 2026, allocated to quiz scores, contest winners and event participants. No per-address source exists for these distributions. The MiCA white paper, the Medium feed and ICO Drops contain no CSV, Merkle dump, Dune dashboard or claim endpoint.
(Source: Alchemy Pay MiCA White Paper (OKX), Alchemy Pay Medium Feed, ICO Drops, Alchemy Pay)
Projects must disclose all material terms of market-making arrangements that affect token liquidity. If the project has no agreements or deals with market makers, state that explicitly; doing so earns full credit. For each market maker, include in a table:
If the project has no agreements or deals with market makers, state that explicitly; doing so earns full credit. If no native tokens were loaned or allocated to market makers, state that explicitly; cash/fiat retainers or fees are not required for this item.
Response
Projects must disclose all material terms of centralized or decentralized exchange listings that affect token liquidity. For each listing, include in a table:
If the project has no agreements or deals with CEX or DEX, state that explicitly; doing so earns full credit; cash/fiat fee amounts are not required for this item.
Response
Disclose all prior token sales by the Project — including fundraising rounds, any material OTC sales to investors, and any discounted market-maker sales. For each sale, provide:
If no prior sales occurred, state that explicitly (e.g., "No prior fundraising, OTC, or discounted MM sales have occurred.").
Response
If any, list prior exploits or incidents that directly affected the token, token supply, tokenholder balances, token contract, minting controls, burn mechanics, or custody of token supply. This question is not asking about general protocol, application, or smart contract exploits unless the incident directly affected the native token itself. If no prior incidents, state this explicitly (e.g., "No exploits affecting tokenholders or protocol funds as of YYYY-MM-DD").
Response
No exploits affecting tokenholders or protocol funds have been publicly reported as of 2026-10-05. The review covered the MiCA white paper, Alchemy Pay's monthly updates on Medium through October 2026, news coverage of ACH and the ACH contract's supply history on Ethereum.
(Source: Alchemy Pay MiCA White Paper (OKX), Alchemy Pay Medium Feed, Blockscout, ACH Token)
Not applicable. No exploit vector affecting ACH is on the public record.
(Source: Alchemy Pay MiCA White Paper (OKX))
Not applicable. No reported incident affected ACH balances or custody. Onchain total supply equals the 10,000,000,000 initial supply plus the 5,346,246,088 ACH minted by the authorised Safe on April 9, 2026, so no unauthorised mint appears in the supply record.
(Source: , )
Describe material risk factors across the three categories below. Each category includes prompts to address at a minimum.
(a) Regulatory, Legal & Tax Risks — Describe how evolving laws and regulations could affect the project by answering, at a minimum, questions like:
Impact of Regulatory Change on TGE and Listings: (If applicable) How could evolving or conflicting laws and regulations affect your ability to complete the TGE, deliver tokens to purchasers, and list or maintain the token on trading venues in key jurisdictions?
Entity-Level Regulatory Impact: (If applicable) How could regulatory or legal changes impact your core entities (Foundation, DevCo, DAO, affiliated service providers), including enforcement actions, licensing requirements, or forced changes to structure or operations?
Tokenholder Tax Treatment: (If applicable) What uncertainties exist around how tokenholders may be taxed, and make clear that tokenholders are responsible for understanding their own tax obligations?
Jurisdictional & User Access Restrictions: (If applicable) If the project restricts access for certain jurisdictions or user types (e.g., U.S. persons, sanctioned countries, retail vs. professional), what are those restrictions and what risks do they create for users and for the project?
(b) Protocol, Technology & Security Risks — Describe risks to network and contract reliability, correctness, and safety by answering, at a minimum, questions like:
Bugs and Design Flaws: (If applicable) What bugs, design flaws, or implementation errors could exist in your core protocol code, smart contracts, and any bridges, rollups, or oracles that you depend on, and how could these lead to loss of funds or disruption of the protocol?
Security Measures & Their Limitations: (If applicable) What security measures have you taken (audits, formal verification, bug bounties), and what types of failures might these measures still fail to detect or prevent?
(c) Token Economics, Unlocks & Incentive Risks — Describe how the token's economic design and supply schedule could affect holders by answering, at a minimum, questions like:
Critical Economic Assumptions: (If applicable) Which economic assumptions (e.g., staking yields, fee revenue, liquidity incentives, MEV capture, demand for blockspace) are critical for protocol security, utility, and governance, and what happens if those assumptions fail?
This Token Transparency Filing is provided for general informational purposes only and does not verify or warrant the accuracy of individual answers.
No airdrop planned or conducted
Not applicable. The committee has run community reward campaigns paid in ACH.
Not applicable. No token exploit required remediation. The MiCA white paper reports an automated Cyberscope audit of the token contract that found no critical vulnerabilities.
(Source: Alchemy Pay MiCA White Paper (OKX))
Not applicable. No token incident is open, under investigation or in litigation as of 2026-10-05.
No post-mortem exists because no token exploit occurred. The MiCA white paper and its reference to the Cyberscope audit are the reviewed references.
(Source: Alchemy Pay MiCA White Paper (OKX))
Governance Control over Monetary Policy & Rewards: (If applicable) To what extent can governance change monetary policy, fee parameters, or reward allocations (e.g., inflation rate, treasury flows, incentive programs), and how could such changes adversely affect tokenholders?
Response
Impact of Regulatory Change on TGE and Listings:
ACH's TGE is complete, and its EU access rests on a MiCA white paper filed by OKX Europe Limited for admission to trading on its Malta-licensed platform, with no public offer by the issuer. A change in MiCA rules, a regulator challenge to the white paper or a delisting decision by OKX's listing committee could restrict EU trading, and exchanges elsewhere could delist ACH under their own rules. The white paper warns that ACH services may not be available in all jurisdictions and that periods of low liquidity may occur.
(Source: Alchemy Pay MiCA White Paper (OKX))
Entity-Level Regulatory Impact:
The issuer, Alchemy GPS Europe UAB, is regulated in Lithuania, its parent operates from Singapore and the group holds money transmitter licenses in 19 U.S. states plus registrations in Australia, South Korea and Switzerland. Each license brings supervision, and a loss of license, an enforcement action or new rules in any of these places could force changes to operations or end services in that market. The MiCA white paper flags regulatory and enforcement risk and notes that the issuer may not publish financial statements, which limits holder visibility into its financial health.
(Source: Alchemy Pay MiCA White Paper (OKX), Alchemy Pay Michigan Money Transmitter License)
Tokenholder Tax Treatment:
Alchemy Pay and the MiCA white paper give no tax guidance for receiving, holding, pledging or trading ACH. Rewards and promotional distributions may be taxed as income on receipt in some jurisdictions and only on disposal in others, and tokens released from the 2026 vesting contracts may raise timing questions for recipients. Tokenholders are responsible for understanding their own tax obligations.
(Source: Alchemy Pay MiCA White Paper (OKX), Alchemy Pay Medium Feed)
Jurisdictional & User Access Restrictions:
The MiCA white paper lists the EEA member states where ACH is admitted to trading through OKX Europe and warns that ACH services or token utility may not be available in every jurisdiction. Alchemy Pay's payment services depend on local licensing, so users in states or countries without coverage may lose access to the gateway and to the main token use, which narrows the holder base and could reduce demand.
(Source: Alchemy Pay MiCA White Paper (OKX), Alchemy Pay Michigan Money Transmitter License)
Bugs and Design Flaws:
The ACH contract is mintable with no supply cap and pausable by a single externally owned address, so a compromised minter Safe could inflate supply and a compromised pauser key could halt all transfers. The five TokenVesting contracts holding about 5.13 billion ACH as of 2026-10-06 are revocable by one externally owned owner address. ACH also exists on BNB Smart Chain, and the MiCA white paper flags bridge and interoperability risk between chains. Alchemy Chain is a new Layer-1 that launched in May 2026, and its bridge and consensus design are not described in technical detail in the sources reviewed.
(Source: Blockscout, ACH Token, Blockscout, Minter Safe, Blockscout, TokenVesting 0xEae8, Blockscout, TokenVesting 0x7D56, Blockscout, TokenVesting 0xF72E, Blockscout, TokenVesting 0x1918, Blockscout, TokenVesting 0x174E, Alchemy Pay MiCA White Paper (OKX), The Alchemy Chain Mainnet Is Live)
Security Measures & Their Limitations:
The MiCA white paper reports one automated Cyberscope audit of the token contract with no critical findings. Minting requires three of six Safe signatures, which guards against a single compromised key, but the signers are unnamed and the April 2026 mint of 5.35 billion ACH shows the Safe can issue large amounts in one transaction. An automated audit cannot detect key compromise, misuse of admin roles or flaws in the new chain and bridge, and no bug bounty or formal verification is disclosed.
(Source: Alchemy Pay MiCA White Paper (OKX), Blockscout, Minter Safe, Etherscan, April 9 2026 Mint Transaction)
Critical Economic Assumptions:
ACH demand depends on enterprise partners pledging tokens and on gas use on Alchemy Chain, since holders receive no revenue share. The supply framework assumes that new issuance will fund validators, developers and integrations that grow payment activity. Onchain supply already stands at 15.35 billion ACH, about 53% above the 10 billion described in the MiCA white paper, and about 5.13 billion ACH (as of 2026-10-06) will keep releasing from vesting contracts through 2036. If chain usage and pledging stay low while these releases continue, selling pressure could weigh on price.
(Source: ACH Supply Framework (Cryptowisser), Alchemy Pay MiCA White Paper (OKX), Blockscout, ACH Token, Blockscout, TokenVesting 0xEae8, Blockscout, TokenVesting 0x7D56, Blockscout, TokenVesting 0xF72E, Blockscout, TokenVesting 0x1918, Blockscout, TokenVesting 0x174E)
Governance Control over Monetary Policy & Rewards:
Monetary policy is controlled by the management committee and the minter Safe, not by tokenholders. The Safe minted the full 2037 supply projection in April 2026, before the May community vote on the schedule, and the vote result is not published. The committee also directs treasury spending on rewards and rebates, and the vesting owner can revoke unvested tokens. These parties can change issuance, release timing and reward flows without a binding holder vote, which could dilute holders or shift value away from them.
(Source: Blockscout, Minter Safe, Etherscan, April 9 2026 Mint Transaction, ACH Supply Adjustment Vote (TradingView), Alchemy Pay MiCA White Paper (OKX), Blockscout, TokenVesting 0xEae8, Blockscout, TokenVesting 0x7D56, Blockscout, TokenVesting 0xF72E, Blockscout, TokenVesting 0x1918, Blockscout, TokenVesting 0x174E)
