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
Public EVM blockchains expose transaction details, balances and smart contract inputs to anyone by default. The COTI V2 technical whitepaper names this lack of confidentiality as a barrier for users, enterprises and applications that handle private data. COTI builds a privacy layer based on garbled circuits and multiparty computation so that applications can compute on encrypted data without revealing it.
(Source: COTI V2 Technical Whitepaper)
Under the V2 monetary policy, each new mint is split 58% to community rewards, 24% to the COTI Foundation for ecosystem growth and 18% to development, which gives the project a recurring token budget. The COTI Foundation also earmarked 400 million COTI, valued at $25 million at its announcement, for an Ecosystem Growth Fund. In August 2026 the team announced that COTI Earn would pause at the end of its current season, along with the Treasury and the Nodes v2 launch, to concentrate resources on enterprise privacy and Privacy-on-Demand. On September 21, 2026 current management stepped down and ZK Foundation, led by Robbie Vander, took over direction of COTI with a pivot to spendable private payments and a COTI 2.0 campaign.
(Source: COTI V2 Technical Whitepaper, Decrypt, COTI Launches $25M Ecosystem Growth Fund, COTI Medium Feed, August 2026 Posts, TradingView, ZK Foundation Takes Over Direction of COTI)
COTI V2 is described in its whitepaper as an EVM-compatible confidential computing Layer 2 for Ethereum. Garbled circuits let smart contracts can process private inputs while the chain stays compatible with Ethereum tooling. Through Privacy-on-Demand, COTI plans to bring its garbled circuits to other Layer 1 and Layer 2 chains in 2026, with cross-chain privacy fees charged in COTI. The original COTI V1 network launched in 2019 as a DAG-based payments network, and V1 tokens migrate to V2 at a 1 to 1 ratio. The coti.io website now presents COTI as a privacy coin for spending, with travel booking, a crypto card and a VPN in early access.
(Source: COTI V2 Technical Whitepaper, COTI Tokenomics Update, March 2026, COTI Token Economy 2019, COTI Tokenomics FAQ, COTI Website)
COTI pays gas on the COTI V2 network, including the higher gas charged for private transactions, and pays privacy bridge and cross-chain Privacy-on-Demand fees. It was staked for rewards through the COTI Treasury until the August 2026 pause, and then through an 18% APR flexible staking promotion on KuCoin that ran from August 11 to September 10, 2026. No successor staking program had been announced as of 2026-10-05. On coti.io, COTI is accepted for travel bookings, pays VPN subscriptions and is paid out as card cashback. Governance voting runs through gCOTI, a separate token, and not through COTI itself.
(Source: COTI Tokenomics Update, March 2026, COTI Medium Feed, August 2026 Posts, KuCoin COTI Flexible Promotion, COTI Website, gCOTI Governance FAQ)
Control of COTI rests with the project team and the COTI Foundation, and on September 21, 2026 direction passed to ZK Foundation. The Foundation holds the community rewards allocation and makes annual burn proposals, and the ERC20 COTI contract on Ethereum is owned by a single externally owned address that can still mint. gCOTI holders vote on community treasury matters, including whether to burn accumulated gas fees, and the governance FAQ states that the governance page is being reworked for V2. In August 2026 the team said it is reconsidering the future of gCOTI, so the governance model is in flux.
(Source: TradingView, ZK Foundation Takes Over Direction of COTI, COTI Tokenomics Update, March 2026, Blockscout, ERC20 COTI Contract, gCOTI Governance FAQ, COTI Medium Feed, August 2026 Posts)
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 |
|---|---|---|---|
Shahaf Bar-Geffen | Labs/DevCo | CEO of Coti, whose website is operated by Coti (BVI) Limited, until current management stepped down in the September 21, 2026 handover to ZK Foundation, after which he continues with COTI as an advisor (SEC v. Binance Complaint Excerpt on COTI, COTI Foundation on X, September 21, 2026, TradingView, ZK Foundation Takes Over Direction of COTI) | Co-founder and CEO of the digital marketing firm WEB3 from 2006 to 2016, co-founder and director of Positive Mobile and Maple, chairman of Uncaged Studios and a Major in the Israeli Air Force reserves. He holds a BSc in biotech and economics from Tel Aviv University and joined COTI as an early investor and advisory board member before becoming CEO (CryptoSlate, Shahaf Bar-Geffen, KuCoin AMA with COTI). |
Nir Haloani | Labs/DevCo | Named CTO of COTI in the June 2019 KuCoin AMA. The September 21, 2026 handover announcement does not name him, and no source dated after the handover confirms his current role (KuCoin AMA with COTI) | Holds a mathematics PhD and 14 patents, sold a company to IBM and served as its head of research, and holds the Master Inventor title in data compression, AI and machine learning (KuCoin AMA with COTI). |
Samuel Falkon and David Assaraf | Labs/DevCo | Co-founders of Coti as named in the SEC complaint against Binance (SEC v. Binance Complaint Excerpt on COTI) | The reviewed sources do not disclose their prior experience or whether they hold current roles. |
Eyal Wagner | Foundation | Head of the board of the COTI Foundation at its launch in November 2023 (Introducing the COTI Foundation) | Fintech executive with over 15 years of experience and CEO of brokerage firms during the sale of Leverate to Saxo Bank in 2011 and of Markets.com to Playtech in 2015. He sat on the COTI board from 2017 to 2018 and founded Castle Rock, a Gibraltar fund manager, and Cole Capital, an algorithmic trading fund, in 2020 (Introducing the COTI Foundation). |
Robbie Vander | Foundation | Leader of ZK Foundation, which took over direction of COTI on September 21, 2026 in a foundation handover (COTI Foundation on X, September 21, 2026, TradingView, ZK Foundation Takes Over Direction of COTI) | The handover announcement describes him only as having deep experience in the web3 venture space and names no prior roles. The reviewed sources do not disclose his prior experience or the legal form of ZK Foundation (COTI Foundation on X, September 21, 2026). |
No DAO entity exists for COTI. Treasury votes are open to all native gCOTI holders, and no officers, council or delegates are named (gCOTI Governance FAQ). | DAO/Onchain Governance | No individual holds a DAO title, because gCOTI voting has no officeholders (gCOTI Governance FAQ). | 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 COTI, and no DAO owns or controls IP. The coti.io website is operated by Coti (BVI) Limited, and the COTI Foundation describes itself as the body that funds and supports the network. Neither entity has published a statement assigning the codebase or the COTI brand to holders.
(Source: SEC v. Binance Complaint Excerpt on COTI, COTI Foundation FAQ)
gCOTI holders hold no onchain pause, upgrade or executor authority over the COTI contracts. Their power is a vote on community treasury matters, where the option backed by the most gCOTI wins under a simple plurality and voting power is set by a random snapshot taken within 24 hours after the vote closes. The whitepaper describes planned quorum rules and smart-contract execution for V2 governance, and the reviewed sources show no deployed governance executor. The ERC20 COTI contract is owned by the externally owned address 0xcd50cfd2f94841858e7c702e1505994fa498a577, which can mint new tokens because minting has not been finished, and the owner's identity is not disclosed.
(Source: gCOTI Governance FAQ, COTI V2 Technical Whitepaper, Blockscout, ERC20 COTI Contract, Blockscout, ERC20 COTI Owner Address)
gCOTI held in a wallet and gCOTI deposited in the COTI Treasury both count toward voting power. The Treasury was paused on August 18, 2026 at 10 a.m. UTC, with all deposits, top-ups and boosts paused, so no locking mechanism is currently open. Holders could decide treasury questions put to a vote, such as burning accumulated gas fees, and could not change the mint schedule outside that process.
(Source: gCOTI Governance FAQ, COTI V2 Technical Whitepaper, COTI Medium Feed, August 2026 Posts)
COTI holders have no right to protocol revenue. All COTI V2 gas fees accrue to a community-controlled wallet, and the community treasury can vote to burn them. Half of privacy bridge and Privacy-on-Demand fees are burned and the other half goes to the Foundation. Staking rewards are paid from the 58% community rewards share of new mints, and the last reward program, an 18% APR flexible staking promotion on KuCoin, ran from August 11 to September 10, 2026. No successor reward program had been announced as of 2026-10-05.
(Source: COTI Tokenomics Update, March 2026, COTI Medium Feed, August 2026 Posts, KuCoin COTI Flexible Promotion)
No DAO exists, so no party holds authority to dissolve one. The governance FAQ, the whitepaper and the tokenomics posts describe no legal wrapper and no wind-down vote.
(Source: gCOTI Governance FAQ, COTI V2 Technical Whitepaper)
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
The COTI Foundation is an independent non-profit organization launched in November 2023 to drive adoption of the COTI network. Its jurisdiction, registration number and legal form are not disclosed in the launch post, the Foundation FAQ or the website. On September 21, 2026 ZK Foundation, led by Robbie Vander, took over direction of COTI in what was described as a foundation handover, and its jurisdiction and its legal relationship to the COTI Foundation are also undisclosed.
(Source: Introducing the COTI Foundation, COTI Foundation FAQ, TradingView, ZK Foundation Takes Over Direction of COTI)
The Foundation discloses no IP ownership, no trademark registrations and no subsidiaries. Its stated role is funding and supporting the ecosystem through grants, education and infrastructure development, while the coti.io website is operated by Coti (BVI) Limited.
(Source: Introducing the COTI Foundation, SEC v. Binance Complaint Excerpt on COTI)
The Foundation receives 24% of each V2 mint and manages the Ecosystem Fund, which was allocated two tranches of 200 million COTI from existing supply. In August 2026 it held nearly 329 million COTI of community rewards in a dedicated cold wallet, with monthly emissions from the 58% rewards share routed to the same wallet, and it decides how those tokens are spent on staking, airdrops, exchange campaigns and liquidity. It makes annual burn proposals and committed to burn at least 100 million COTI within 12 months of March 2026. It also receives half of privacy bridge and Privacy-on-Demand fees. None of these powers is subject to a published vote threshold.
(Source: COTI V2 Technical Whitepaper, COTI Foundation FAQ, COTI Medium Feed, August 2026 Posts, COTI Tokenomics Update, March 2026)
The Foundation discloses no ownership of or contractual control over Coti (BVI) Limited. The two share history, since board head Eyal Wagner sat on the COTI board from 2017 to 2018, and the September 2026 handover placed overall direction of COTI with ZK Foundation, which indicates foundation-level influence over the development team. The terms of that handover are not published.
(Source: Introducing the COTI Foundation, TradingView, ZK Foundation Takes Over Direction of COTI)
The Foundation does not disclose which keys it holds. The community rewards wallet it announced, 0xb00D3cAb13Fd242c76C86778d3A658eBBd0c2Fc5 on the COTI network, is a single address, and on September 16, 2026 it sent 350,490,727 COTI to the 0x000000000000000000000000000000000000dEaD address and now holds no COTI. The ERC20 COTI contract on Ethereum is owned by a single externally owned address with an open mint function, and no multisig threshold is disclosed for it or for the native chain.
(Source: CotiScan, Community Rewards Wallet, COTI Medium Feed, August 2026 Posts, Blockscout, ERC20 COTI Owner Address)
Three programmatic or adopted mechanisms direct value to the Foundation. It receives 24% of each V2 mint, half of privacy bridge and Privacy-on-Demand fees, and custody of the 58% community rewards share, which it spends on ecosystem programs. It was also allocated two 200 million COTI tranches from existing supply for the Ecosystem Fund, and the Builders Program FAQ describes grants from $1,000 to more than $100,000.
(Source: COTI V2 Technical Whitepaper, COTI Tokenomics Update, March 2026, COTI Foundation FAQ, Builders Program FAQ)
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
Coti (BVI) Limited is a company incorporated and registered in the British Virgin Islands that operates the coti.io website, according to the SEC complaint against Binance. The 2019 token economy paper was issued by COTI Limited with a registered address at Royal Ocean Plaza, Gibraltar. The reviewed sources do not show whether the two companies are related or which one employs the development team today.
(Source: SEC v. Binance Complaint Excerpt on COTI, COTI Token Economy 2019)
The development company operates the coti.io website. No license terms, trademark registrations or subsidiary chart are disclosed, and the reviewed sources do not state which entity owns the COTI V2 codebase or the brand. Soda Labs was named the first grantee of the Ecosystem Fund, and its IP relationship to the company is not described.
(Source: SEC v. Binance Complaint Excerpt on COTI Decrypt, COTI Launches $25M Ecosystem Growth Fund)
No DAO exists. The COTI team ran the Treasury and decided in August 2026 to pause it, to pause COTI Earn and to pause the Nodes v2 launch, all without a holder vote. Earlier, the team ran the bridge between native and wrapped COTI and its automatic burn procedure.
(Source: COTI Medium Feed, August 2026 Posts, Understanding COTI's Supply)
The development company discloses no ownership of or control over the COTI Foundation. The Foundation's board head Eyal Wagner previously sat on the COTI board, which gives the two entities an indirect tie through shared people. Since the September 2026 handover, overall direction of COTI rests with ZK Foundation rather than with the development company's former management.
(Source: TradingView, ZK Foundation Takes Over Direction of COTI, Introducing the COTI Foundation)
No pause, upgrade or executor role is publicly assigned to Coti (BVI) Limited. The ERC20 COTI contract is a 2019 mintable token whose owner, the externally owned address 0xcd50cfd2f94841858e7c702e1505994fa498a577, can mint without a cap, and the reviewed sources do not say which entity controls that key.
(Source: Blockscout, ERC20 COTI Contract, Blockscout, ERC20 COTI Owner Address)
Under the V2 monetary policy, 18% of each new mint is earmarked for development. At the 2019 launch the team was allocated 15% of supply with a minimum six-month lockup and 24-month release, and advisors 10% with locks of 6 to 36 months. No fee or revenue stream is directed to the development company.
(Source: COTI V2 Technical Whitepaper, SEC v. Binance Complaint Excerpt on COTI)
Disclose launch and initial supply details in a single initial allocation schedule covering the token's launch.
Response
All 2,000,000,000 COTI were created at the network genesis and the supply post states they were minted in June 2019. KuCoin listed an initial circulating supply of 3.79%, or about 75,800,000 COTI, at the June 4, 2019 listing, which leaves about 96.21% locked or held in reserve at launch.
(Source: Understanding COTI's Supply, KuCoin Spotlight Announcement, COTI Token Economy 2019)
(Source: KuCoin Spotlight Announcement, SEC v. Binance Complaint Excerpt on COTI, COTI Token Economy 2019)
The KuCoin Spotlight IEO sold COTI at a fixed price of $0.065, paid in KCS, with a hard cap of $3,000,000. Earlier private and seed sales were priced at $0.08 and $0.06. ICO Drops records a price of $0.0901 at listing.
(Source: KuCoin Spotlight Announcement, ICO Drops, COTI)
COTI.
(Source: KuCoin Spotlight Announcement, COTI Tokenomics FAQ)
COTI launched with a fixed supply of 2,000,000,000 and no ability to create or destroy tokens. COTI V2 replaced this with an inflationary schedule from 2025, minting new tokens every 103 hours at an initial periodic rate of 0.45% that declines over a decade and stays adjustable by governance, with burns from fees able to offset issuance. The March 2026 tokenomics update states that maximum supply stays fixed and no new tokens are minted, while the August 2026 rewards post states that programmatic emissions continue and are routed monthly to the rewards wallet. CoinGecko reports a total supply of about 2,979,596,663 COTI and a maximum of 4,910,000,000, and the ERC20 COTI contract on Ethereum reported a total supply of 5,828,234,910 in an onchain read at block 26134865 on 2026-10-06. The contract owner, a single externally owned address, minted about 41,700,000 further ERC20 COTI in several transactions on 2026-10-06, and the minting function is not finished. The project has not published a reconciliation of these figures.
(Source: COTI Token Economy 2019, COTI V2 Technical Whitepaper, COTI Tokenomics Update, March 2026, COTI Medium Feed, August 2026 Posts, CoinGecko API, COTI, Blockscout, ERC20 COTI Token, Etherscan, ERC20 COTI Owner Address Transactions)
(Source: KuCoin Spotlight Announcement, ICO Drops, COTI, SEC v. Binance Complaint Excerpt on COTI)
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. The community rewards allocation is designated for airdrops, and no new airdrop with a published recipient-list commitment has been announced.
(Source: COTI Medium Feed, August 2026 Posts)
Executed airdrop
The record shows one executed distribution. The gCOTI airdrop campaign distributed 8.5% to 10% of the 1,000,000,000 gCOTI supply to COTI Treasury depositors in proportion to the amount deposited, with any remainder going to the gCOTI reserve. The August 2026 rewards post says the 58% community rewards allocation is reserved for uses including exchange campaigns and airdrops, and does not name the segments or the allocation formula. No per-address source has been published for the gCOTI distribution, and the FAQ, the Medium posts and the community rewards wallet contain no CSV, Merkle dump, Dune dashboard or claim endpoint.
(Source: gCOTI Tokenomics FAQ, COTI Medium Feed, August 2026 Posts, CotiScan, Community Rewards Wallet)
No airdrop planned or conducted
Not applicable. The community rewards allocation is designated to fund airdrops.
(Source: COTI Medium Feed, August 2026 Posts)
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
2023-03-22. The incident affected the COTI bridge between native COTI and the wrapped ERC20, BEP2 and BEP20 tokens, specifically three bridge addresses during a live test of an automatic burn procedure.
(Source: Understanding COTI's Supply)
This was an operational error and not a hack. A misconfiguration set the wrong token amount scale for the automatic burn procedure, so the test operated on the three bridge addresses with an incorrect amount of tokens.
(Source: Understanding COTI's Supply)
COTI stated that no funds left the bridge and that there was no security issue. The excess tokens created by the error were burned immediately, and the post does not give the number of tokens involved.
(Source: Understanding COTI's Supply)
COTI burned the excess immediately and changed custody so that part of the bridge funds is moved daily to a cold wallet and to Binance Custody. It also stated that its token balances are regularly audited by top auditing firms, without naming them.
(Source: Understanding COTI's Supply)
Resolved. COTI published its explanation on March 24, 2023, and no later follow-up on the incident was found.
(Source: Understanding COTI's Supply)
The Understanding COTI's Supply post is the only public explanation of the March 2023 bridge incident. No other exploits affecting tokenholders or protocol funds have been publicly reported as of 2026-10-05. The review covered the COTI Medium archive and feed through September 2026, the CertiK Skynet profile and news coverage. The large ERC20 mints and native transfers of September 2026 described in Section 12 have not been reported as an exploit.
(Source: Understanding COTI's Supply, COTI Medium Feed, August 2026 Posts, CertiK Skynet, COTI)
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?
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:
COTI's TGE took place in 2019, so the regulatory exposure now lies in keeping the token listed. In June 2023 the SEC named COTI in its complaint against Binance as a crypto asset offered and sold as a security, citing the 2019 IEO and COTI's own statements about team efforts. The SEC dismissed that case with prejudice on May 29, 2025, which ended the claim. A new enforcement action in the U.S. or a stricter listing standard elsewhere for privacy tokens could lead exchanges to delist COTI and reduce liquidity.
(Source: SEC v. Binance Complaint Excerpt on COTI, PYMNTS, SEC Drops Binance Lawsuit)
Entity-Level Regulatory Impact:
Coti (BVI) Limited operates the website from the British Virgin Islands, the 2019 issuer was COTI Limited in Gibraltar, and the COTI Foundation and ZK Foundation have not disclosed their jurisdictions. That opacity makes it hard for holders to know which regulator or court has authority over the entities. The new direction under ZK Foundation markets no-KYC travel booking, a no-KYC crypto card and bookings in geo-blocked regions such as Russia and China, which raises sanctions and anti-money-laundering exposure and could prompt enforcement, payment-partner withdrawal or forced changes to the products.
(Source: SEC v. Binance Complaint Excerpt on COTI, COTI Token Economy 2019, COTI Website, TradingView, ZK Foundation Takes Over Direction of COTI)
Tokenholder Tax Treatment:
The project publishes no tax guidance for COTI. Staking rewards from KuCoin or the former Treasury, airdrops, referral points converted into app credits and the 1 to 1 migration from V1 to V2 may each be treated as income or as a disposal depending on the holder's jurisdiction. Cashback paid in COTI on card purchases adds another category whose treatment is unsettled. Tokenholders are responsible for understanding their own tax obligations.
(Source: KuCoin COTI Flexible Promotion, COTI Tokenomics FAQ, COTI Website)
Jurisdictional & User Access Restrictions:
The reviewed sources show no published list of restricted jurisdictions for COTI V2 or for the new travel, card and VPN products. V1 tokens left in the Treasury lose access if they are not migrated by the deadline, which shuts out holders who miss the window. COTI stated in 2024 that the V2 protocol would be permissionless and would not require KYC, and the new products advertise no-KYC access. Users in restricted places who rely on these products face the risk of frozen access if partners or exchanges later apply geographic or sanctions controls, and the project faces exposure for serving them.
(Source: COTI Medium Feed, August 2026 Posts, How COTI Is Gearing Up for 2024 and Beyond, COTI Website)
Bugs and Design Flaws:
COTI's privacy depends on new cryptography, garbled circuits and multiparty computation run by network nodes, and a flaw in circuit generation or in the MPC protocol could expose private data or corrupt encrypted balances. The bridge between native and wrapped COTI has already failed once, when a misconfigured burn test in March 2023 used the wrong token scale. The ERC20 COTI contract is a 2019 mintable token whose single owner address can mint without limit, so a compromised or misused key could inflate the wrapped supply. Privacy-on-Demand extends this risk to every partner chain that integrates the protocol.
(Source: COTI V2 Technical Whitepaper, Understanding COTI's Supply, Blockscout, ERC20 COTI Contract, Blockscout, ERC20 COTI Owner Address)
Security Measures & Their Limitations:
CertiK Skynet lists one audit of COTI, last delivered on August 27, 2021, which predates COTI V2 and its privacy stack. COTI moves part of the bridge funds daily to a cold wallet and to Binance Custody and stated that top auditing firms regularly audit its balances, without naming them or publishing reports. No bug bounty or formal verification of the V2 contracts or the garbled-circuit implementation was found in the reviewed sources. These measures cannot prevent misuse of the single ERC20 owner key or a flaw in the V2 cryptography that no audit has reviewed.
(Source: CertiK Skynet, COTI, Understanding COTI's Supply, Blockscout, ERC20 COTI Owner Address)
Critical Economic Assumptions:
COTI's model assumes that privacy fees from the COTI network and partner chains will grow enough for burns to offset ongoing emissions, of which 58% goes to rewards and 24% to the Foundation. Rewards have already been cut, with COTI Earn set to pause at the end of its season and the Treasury and Nodes v2 paused, as announced in August 2026, over dilution concerns. Onchain records add uncertainty. On September 16, 2026 the community rewards wallet sent 350,490,727 COTI to a dead address on the COTI network, while the ERC20 contract minted 350,490,727 and 250,000,023 COTI to the address 0x61BF10A1a27B2d99De0a59a06200A62ED579D685, which had funded that wallet. The same address received a mint of 1,378,306,758 COTI on September 6 and moved about 2.58 billion ERC20 COTI to two unlabeled addresses on September 16. No announcement explaining these movements was found, and if those tokens reach the market without matching demand, the price could fall.
(Source: COTI V2 Technical Whitepaper, COTI Medium Feed, August 2026 Posts, CotiScan, Community Rewards Wallet, Blockscout, 0x61BF Wallet, Blockscout, ERC20 COTI Token)
Governance Control over Monetary Policy & Rewards:
The whitepaper makes the inflation rate adjustable through governance, but in practice the team and the Foundation have set monetary policy without holder votes. They introduced the March 2026 burn commitments, paused rewards in August 2026 and decided against burning the rewards allocation after community requests. The Foundation controls the rewards allocation and its spending, the ERC20 owner key can mint, and ZK Foundation now directs the project with a rewritten roadmap. These parties could change emissions, rewards or burns in ways that dilute holders, and gCOTI voting offers no binding check while its future is under review.
(Source: COTI V2 Technical Whitepaper, COTI Tokenomics Update, March 2026, COTI Medium Feed, August 2026 Posts, Blockscout, ERC20 COTI Owner Address, TradingView, ZK Foundation Takes Over Direction of COTI)
This Token Transparency Filing is provided for general informational purposes only and does not verify or warrant the accuracy of individual answers.
