Provide a concise narrative that clearly states each of (a)–(e) below.
Gram (GRAM) is the native token of The Open Network (TON), a proof-of-stake Layer 1 blockchain built to serve as the payments, application, identity, and digital-asset layer for Telegram's roughly one billion users. The network solves the problem of delivering low-cost, sub-second onchain payments and applications to a mainstream messaging audience through Telegram Mini Apps, bots, creator tools, games, and in-app asset flows, backed by a scalable blockchain-and-network stack designed to support millions of transactions per second. (Source: TON.org, TON Whitepaper, TON Primer)
On May 4, 2026, Telegram replaced TON Foundation as the primary steward of The Open Network, taking direct responsibility for product direction, protocol upgrades, and validator participation while becoming the network's largest validator. Development now follows the seven-step Make TON Great Again roadmap that Telegram founder Pavel Durov began publishing in April 2026. Four steps have shipped as of August 2026. These are the Catchain 2.0 consensus upgrade, a sixfold transaction-fee cut, Telegram's assumption of the largest-validator role, and the renaming of Toncoin to Gram. TON Foundation continues to operate as a Swiss non-profit that funds ecosystem growth through grants and support programs, and the protocol continues open-source development with external security audits. (Source: Unchained on Telegram stewardship, MTONGA roadmap explained, The Open Network Foundation, Security audits)
The Open Network is a proof-of-stake, multi-blockchain system composed of a masterchain, workchains, and shardchains, plus auxiliary components covering storage, DNS, proxying, and payments. The Catchain 2.0 consensus upgrade activated on mainnet on April 9, 2026 cut block production time from roughly 2.5 seconds to roughly 400 milliseconds and reduced transaction finality to about one second. A fixed base fee of approximately $0.0005 per transaction took effect on May 1, 2026. TON is the exclusive blockchain infrastructure for Telegram's Mini Apps ecosystem under the partnership expanded in January 2025. (Source: TON Whitepaper, TON Primer, Unchained on Catchain 2.0 and fees, TON-Telegram exclusive partnership)
Gram is the official native currency of The Open Network. It pays gas for transactions and smart-contract execution, funds validator rewards, and can be staked directly or through single nominator contracts, nominator pools, and liquid staking protocols. Tokenholders participate in governance through validator configuration voting and through community referendums on the TON Vote platform. Gram is the only cryptocurrency Telegram accepts for specified non-fiat platform payments under the 2025 TON-Telegram arrangement. The token was renamed from Toncoin to Gram, with the ticker changing from TON to GRAM, effective June 15, 2026 at 12:00 UTC following a community referendum. (Source: Whitepaper overview in TON docs, Nominator pool contracts, TON-Telegram exclusive partnership, KuCoin on the Gram rename)
Protocol changes and monetary-policy changes require validator consensus executed through the onchain Elector and Config system contracts, and nominators participate in configuration voting through pool structures. Community-wide tokenholder referendums also occur through the TON Vote platform, and the June 1 to June 8, 2026 referendum that approved the Gram rename passed with 81.22% of participating voting power. Telegram's May 2026 assumption of the primary-steward and largest-validator roles concentrated protocol influence in a single corporate entity and made TON Foundation a secondary rather than primary entity in governance and development. Validators retain formal authority over consensus parameters, including the pending decisions on post-Catchain 2.0 block-reward levels. (Source: System contracts in TON docs, Phemex on the TON Vote referendum, crypto.news on the 2026 takeover, Nominator pool contracts)
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.
Full Name | Entity | Official Title | Prior Experience |
|---|---|---|---|
Pavel Durov | Labs | Founder and CEO of Telegram, the company that became TON's primary steward and largest validator on May 4, 2026 (Source: Unchained) | Founded VKontakte, Russia's largest social network, and founded Telegram, which he built into a platform with roughly one billion users. He led Telegram's original 2018 Gram fundraising before the SEC settlement forced Telegram's 2020 exit (Source: Phemex profile of Pavel Durov) |
Anatoliy Makosov | Labs | Technical Lead of TON core development (Source: Interview with TON's Technical Lead) | Core developer who continued The Open Network as an open-source community project after Telegram stepped away in 2020 (Source: Interview with TON's Technical Lead, TON Primer) |
Maximilian Crown | Foundation | President of the Foundation Council and CEO of TON Foundation. He became CEO in April 2025 and added the President role in August 2025 (Source: TON Foundation appoints Maximilian Crown as CEO, Max Crown appointed President and CEO, The Open Network Foundation) | Co-founder of MoonPay, where he served as CFO and COO (Source: TON Foundation appoints Maximilian Crown as CEO) |
Gerardo Carucci | Foundation | Chief Marketing Officer (Source: TON Foundation appoints Gerardo Carucci as CMO) | Previously worked at Apple and Nike, including Apple product-launch work and Nike global campaign leadership (Source: TON Foundation appoints Gerardo Carucci as CMO) |
Manuel Stotz | Foundation | Former President of TON Foundation from January 2025 to August 2025. He stepped down to focus on TON Strategy Co., the Nasdaq-listed Gram treasury company (Source: TON Foundation welcomes Manuel Stotz as President, Max Crown appointed President and CEO) | Founder of Kingsway Capital, a London-based investment firm focused on frontier and emerging markets (Source: TON Foundation welcomes Manuel Stotz as President) |
Steve Yun | Foundation | Board member and former President of TON Foundation, having handed the President role to Manuel Stotz in January 2025 (Source: TON Foundation welcomes Manuel Stotz as President) | Public sources identify his prior office as President of TON Foundation. TON Foundation has not published a detailed prior-experience biography for him (Source: TON Foundation welcomes Manuel Stotz as President) |
Barbara Schüpbach | Foundation | Foundation Council Member (Source: The Open Network Foundation) | TON Foundation has not published a detailed prior-experience biography for her (Source: The Open Network Foundation) |
The project does not have a DAO or a fixed onchain governance leadership roster (Source: Nominator pool contracts, Interview with TON's Technical Lead) | DAO | Not applicable | Governance operates through validator voting, nominator participation in configuration voting, and community referendums on TON Vote rather than a standing DAO executive body (Source: Nominator pool contracts, Phemex on the TON Vote referendum) |
Blockworks note: Since May 4, 2026, Telegram has been the primary steward of The Open Network and its largest validator, making Telegram leadership the closest equivalent to a Labs/DevCo leadership surface. TON Foundation maintains a publicly identified leadership team through official appointment announcements and its Foundation Council page. The project has no formal DAO officeholder body. Governance leadership operates through validators, the Foundation Council, and open-source contributors. (Source: Unchained on Telegram stewardship, The Open Network Foundation, Interview with TON's Technical Lead Anatoliy Makosov) |
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).
The project does not have a DAO or a DAO legal wrapper, so no DAO owns or controls project IP. The Open Network operates on an open-source codebase with no single controlling authority, and TON Foundation describes itself as one of many contributors in a decentralized community. (Source: The Open Network Foundation, Interview with TON's Technical Lead)
The project does not have a DAO executor. Onchain governance authority sits in the Elector and Config system contracts. Elector manages validator elections, validation rounds, reward distribution, and complaint handling. Config manages configuration parameters, validator set updates, and proposal voting. Complaint approval requires more than two-thirds of total validator weight, and configuration proposals are approved after the required rounds with at least three-fourths weighted votes. Validators vote on governance offers, election entry, and complaints through validator wallets. Community-wide referendums also run on the TON Vote platform, and the June 2026 referendum that renamed Toncoin to Gram passed with 81.22% of participating voting power. (Source: System contracts in TON docs, Validator tooling in TON docs, Phemex on the TON Vote referendum)
Staking exists through single nominator contracts, nominator pools, and liquid staking protocols. Nominators participate in configuration voting through pool structures, and some liquid staking protocols allow governance influence. Staked tokenholders can influence validator configuration decisions. They cannot direct TON Foundation funds or treasury distributions, because no DAO body with those powers exists. (Source: Staking overview in TON docs, Nominator pool contracts)
Tokenholders hold no rights over revenue distribution or treasury assets because the project has no DAO legal wrapper. The protocol burns 50% of transaction and storage fees under the mechanism validators and the community approved in 2023, which reduces supply for all holders but distributes no revenue to them. (Source: TON holders and validators vote for the real-time burn, The Open Network Foundation)
The project does not have a DAO, so no DAO dissolution or wind-up authority exists. TON Foundation, as a Swiss non-profit legal entity, is governed by Swiss law and its own council rather than by any onchain dissolution mechanism. (Source: The Open Network Foundation, TON Foundation founded in Switzerland)
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.
The Open Network Foundation (TON Foundation) is a Swiss non-profit organization established in Switzerland in 2023 and officially launched on September 6, 2023. It is based in Zug, Switzerland, with its registered address at c/o Sielva Management SA, Gubelstrasse 11, 6300 Zug. The Foundation's terms identify its legal seat in Zug and place terms disputes under the exclusive jurisdiction of the ordinary courts of Zug. (Source: TON Foundation founded in Switzerland, TON Foundation Privacy Policy, Terms of Use)
TON Foundation has not published a complete inventory of the IP it owns or controls. The Open Network operates on an open-source codebase that allows contributions from anyone, and the Foundation presents itself as offering coordination, support, and grants for TON projects rather than as a sole IP-holding controller. The Foundation has not publicly disclosed any subsidiary entities. (Source: The Open Network Foundation)
TON Foundation holds no formal onchain voting thresholds over governance, treasury actions, or reward parameters. The Foundation states that it empowers projects without controlling TON technology and that TON has no single controlling authority. Validator set updates and proposal voting sit in the Config contract, and validator elections and reward distribution sit in the Elector contract. Since May 4, 2026, Telegram has replaced the Foundation as the network's primary steward, and the Foundation now occupies a secondary role in governance and development while continuing to hold significant Gram tokens and ecosystem resources. (Source: The Open Network Foundation, System contracts in TON docs, crypto.news on the 2026 takeover)
TON Foundation exercises no publicly disclosed power over Telegram's decision-making. Telegram operates independently of the Foundation and displaced it as the network's primary steward in May 2026, which places directional influence with Telegram rather than with the Foundation. (Source: Unchained on Telegram stewardship, crypto.news on the 2026 takeover)
TON Foundation holds no standing pause, upgrade, or governance-executor authority. Configuration changes and validator set updates run through the Config contract, and validator elections and reward distribution run through the Elector contract. A temporary emergency key assigned to the Foundation in 2021 accelerated fixes but could not alter contracts, and that key was retired on November 22, 2023. (Source: System contracts in TON docs)
TON Foundation is a non-profit funded by community contributions and has no equityholders. It directs resources outward through grants, coordination, and ecosystem programs, including The Open League, which allocated 30 million tokens worth $115 million in community rewards in its first full season, a 5 million token DeFi incentive program, and market-structure partnerships such as the SCRYPT institutional stablecoin relationship. No governance-approved, contractual, or programmatic mechanism directs protocol-controlled fees, revenue, or treasury distributions to the Foundation, its contributors, or other participants. (Source: The Open Network Foundation, The Open League Season 1, 5 Million Toncoin DeFi Incentive Program, TON partners with SCRYPT)
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.
No development company was directly involved in issuing the current token at launch. The launch-era distribution occurred through open Proof-of-Work Giver mining after Telegram abandoned the original Gram launch in 2020. Telegram Group Inc. and its wholly owned subsidiary TON Issuer Inc. developed the original network and attempted the predecessor Gram issuance before the SEC settlement. Since May 4, 2026, Telegram has functioned as the network's primary steward and largest validator, taking direct responsibility for product direction, protocol upgrades, and validator participation, and it is now the closest equivalent to a DevCo for the project. Telegram has not publicly disclosed the specific legal entity or jurisdiction through which it performs this stewardship role. (Source: TON Primer, SEC settlement press release, Unchained on Telegram stewardship)
Telegram has not publicly disclosed an IP ownership map for its TON stewardship role. The codebase is open source and derives from the original whitepaper and Telegram-developed code that the community continued after 2020, and no publicly disclosed entity holds exclusive rights over it. (Source: Interview with TON's Technical Lead, Whitepaper overview in TON docs)
Telegram holds no publicly disclosed unilateral powers over treasury actions, token administration, or reward parameters. Protocol changes and monetary-policy changes require validator consensus through the Elector and Config contracts. Telegram's influence operates through its position as the network's largest validator and primary steward rather than through a disclosed contractual control framework, and that validator position gives it the single largest voice in validator votes, including votes on issuance parameters. (Source: System contracts in TON docs, Our Crypto Talk on the validator takeover, Unchained on Telegram stewardship)
Telegram displaced TON Foundation as the network's primary steward in May 2026, which reduced the Foundation to a secondary role in governance and development. No formal framework granting Telegram direct authority over the Foundation's internal decision-making has been publicly disclosed. (Source: crypto.news on the 2026 takeover, Unchained on Telegram stewardship)
Telegram holds no publicly disclosed pause, upgrade, or governance-executor authority over TON contracts. Configuration and validator-set authority sits in the Config and Elector contracts, where complaint approval requires more than two-thirds of total validator weight and configuration proposals require at least three-fourths weighted votes across the required rounds. (Source: System contracts in TON docs, Validator tooling in TON docs)
Telegram earns validator rewards on its staked position as the network's largest validator, under the same protocol issuance rules that apply to all validators. Beyond those validator rewards, no governance-approved, contractual, or programmatic mechanism directing protocol-controlled resources, treasury assets, fees, or token distributions to Telegram or its equityholders has been publicly disclosed. (Source: Our Crypto Talk on the validator takeover, Coin Edition on the validator role)
Disclose launch and initial supply details in a single initial allocation schedule covering the token's launch.
The token launched with an initial supply of 5,000,000,000. All launch supply was unlocked. 98.55% of the supply was transferred to Proof-of-Work Giver smart contracts beginning in July 2020 for open mining-based distribution, and 1.45% was distributed to testers and developers from the 2019 testnet phase. No tokens were contractually locked at launch. (Source: TON Primer, Mining history on TON.org, PRNewswire on the Giver distribution)
No fixed TGE price was set. The token launched through the Proof-of-Work Giver mining process, and the effective acquisition price was determined by the cost of mining hardware and electricity rather than by an offering price. (Source: TON Primer)
The token trades under the ticker GRAM with the name Gram, effective June 15, 2026 at 12:00 UTC. It previously traded under the ticker TON with the name Toncoin, and exchanges displayed the asset as Gram (prev. Toncoin) during the June 2026 transition period. (Source: KuCoin on the Gram rename, CoinMarketCap Gram page)
The supply is not fixed. The initial supply was 5,000,000,000, total supply stands at approximately 5.2 billion as of August 2026, and circulating supply stands at approximately 2.76 billion. New tokens are issued continuously as validator block rewards, historically at 1.7 tokens per masterchain block and 1 token per basechain block, producing roughly 0.6% annual inflation before 2026. The protocol has burned 50% of transaction and storage fees since June 17, 2023 under the real-time burn mechanism approved by holders and validators. The Catchain 2.0 upgrade of April 9, 2026 increased block frequency and lifted issuance, and net annual inflation ran at approximately 1.37% as of July 2026, with roughly 568,726 tokens added to supply daily after burns. Validators took up a June 2026 proposal to cut block rewards to 0.35 tokens per masterchain block and 0.2 tokens per basechain block to stabilize issuance at the faster block rate. (Source: Criptolog supply data, CoinMarketCap Gram page, TON holders and validators vote for the real-time burn, ETHNews on Gram issuance, Coinpaper on the reward-cut proposal)
No conventional investor or team vesting schedule applied to the launch distribution. Open mining from the Giver contracts ran until June 28, 2022, when the initial distribution phase completed. In February 2023, more than 75% of validators voted to freeze 171 dormant early-mining wallets holding 1,081,389,417 tokens, more than 20% of total supply, for 48 months. Those tokens remain frozen until February 21, 2027, after which they unlock. (Source: Mining history on TON.org, Unchained on the wallet freeze, Coincu on the freeze vote)
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.
Blockworks note: TON Foundation has run post-launch ecosystem incentive programs that included airdrop-labeled components. The Open League's first full season allocated 30 million tokens across league rewards, token mining, quests and airdrops, and liquidity-pool boosts, directed at user activity inside TON ecosystem projects. These programs are ecosystem incentives rather than a TGE airdrop. (Source: The Open League Season 1)
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.
Blockworks note: The project has not publicly disclosed any market-maker agreements involving native-token allocations or loans. The one publicly disclosed market-liquidity arrangement is Bybit's RFQ-liquidity support for TON Space under the Mirana partnership, which does not disclose token-loan percentages or other agreement economics. (Source: Mirana backs Toncoin with $8 million)
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.
Blockworks note: Public sources identify DEX-liquidity and exchange-integration arrangements spanning named DEX pools, mutual-listing support, and broad USDt-on-TON exchange and wallet distribution. Native-token listing-fee amounts and per-listing token-allocation percentages have not been publicly disclosed for any of these arrangements. Exchanges updated the token's display name and ticker from Toncoin (TON) to Gram (GRAM) following the June 15, 2026 rebrand, with the ecosystem targeting full consistency by June 22, 2026. (Source: 5 Million Toncoin DeFi Incentive Program, Mirana backs Toncoin with $8 million, USDt on TON on over 100 platforms, KuCoin on the Gram rename)
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.").
Blockworks note: The current token was not sold in any fundraising round. Its entire launch distribution occurred through Proof-of-Work Giver mining with no ICO, IEO, or token sale. The only prior token sale in the project's lineage is the predecessor Gram fundraising conducted by Telegram Group Inc. and TON Issuer Inc. in 2018, which raised $1.7 billion through the sale of approximately 2.9 billion Grams to 171 initial purchasers worldwide. Those Grams were never issued. The SEC obtained a preliminary injunction in March 2020, and the June 26, 2020 final judgment imposed a Section 5 injunction, a three-year 45-day notice requirement for future digital-asset issuances, disgorgement of $1.224 billion subject to offsets, and an $18.5 million civil penalty. The current network's June 2026 rename of Toncoin to Gram restored the original token name without creating a new token or any new sale. (Source: TON Primer, SEC settlement press release, SEC v. Telegram final judgment, Doc. 242, crypto.news Gram rebrand guide)
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").
No exploits affecting tokenholders or protocol funds have been publicly reported as of 2026-08-24.
No exploits affecting tokenholders or protocol funds have been publicly reported as of 2026-08-24.
No exploits affecting tokenholders or protocol funds have been publicly reported as of 2026-08-24.
No exploits affecting tokenholders or protocol funds have been publicly reported as of 2026-08-24.
No exploits affecting tokenholders or protocol funds have been publicly reported as of 2026-08-24.
No exploits affecting tokenholders or protocol funds have been publicly reported as of 2026-08-24.
Blockworks note: TON's April 25, 2025 bridge-retirement announcement states that the legacy Toncoin Bridge processed 31,893 transfers totaling 101,228,451 tokens over four years with zero successful hacks or exploits, and that all transfers remained claimable during wind-down. (Source: TON retires legacy Toncoin Bridge)
CertiK's August 7, 2023 formal-verification writeup identified two accounting-invariant violations in the masterchain elector and config contracts, comprising one minor balance inaccuracy and one process_new_stake path that could leave surplus funds above max_stake indefinitely locked and lost to the user. These were verification findings rather than a realized exploit, and no protocol-fund loss occurred. (Source: CertiK formal verification of TON masterchain contracts)
The project maintains preventative security controls, including a public bug bounty, validator and node alerting tooling, multiple third-party audits, and a Chainalysis incident-response retainer. (Source: TON bug bounty, Telegram alerting in TON docs, Security audits, Chainalysis incident-response program)
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?
The project carries a live securities-enforcement history. The SEC enjoined the predecessor Gram sale, Grams were never issued, and Telegram settled by returning more than $1.2 billion to investors and paying an $18.5 million penalty. The June 2026 restoration of the Gram name to the token, together with Telegram's May 2026 return as the network's primary steward and largest validator, ties the current asset more closely to the entity and branding involved in that enforcement action. Securities-law enforcement can materially disrupt token delivery, listings, and distribution channels where regulators view token distributions or stewardship arrangements as unregistered offerings. (Source: SEC settlement press release, crypto.news on the 2026 takeover, crypto.news Gram rebrand guide)
Regulatory or legal changes could affect all three core organizational surfaces. TON Foundation's terms identify its legal seat in Zug, Switzerland and place terms disputes under the exclusive jurisdiction of the ordinary courts of Zug, while also stating that the Foundation does not and cannot control activity or data on the network, so Swiss regulatory changes could affect the Foundation's structure and programs. Telegram now carries direct operational exposure as primary steward and largest validator, and adverse regulatory action against Telegram in the US or EU, including founder-specific legal proceedings involving Pavel Durov in France, would transmit directly to the network. The project also relies on Telegram-linked distribution, broad stablecoin-market access, and regulated payment and institutional rails through partners such as SCRYPT and Banxa, so licensing changes affecting those channels could impair token access and ecosystem distribution. (Source: Terms of Use, CoinShares institutional research note, TON partners with SCRYPT, TON Foundation partners with Banxa, USDt on TON on over 100 platforms)
The project provides no tax advice to tokenholders. Tokenholders are responsible for determining their own tax treatment under applicable law, including where staking rewards, incentive distributions, NFT transfers, stablecoin flows, or Telegram-platform payments create taxable events, and where the June 2026 rename creates recordkeeping questions across the Toncoin and Gram labels. (Source: Become a Validator, The Open League Season 1, KuCoin on the Gram rename)
The project has not published a detailed jurisdiction-blocking policy. The token's availability depends on Telegram distribution, exchange and wallet integrations, and regulated payment rails, so future sanctions rules, exchange onboarding standards, payment-partner licensing changes, platform restrictions, or other jurisdictional constraints could limit user access or token utility in specific markets. (Source: Terms of Use, USDt on TON on over 100 platforms, TON Foundation partners with Banxa)
TON's public technical materials identify concrete smart-contract and protocol risk surfaces. Current security guidance warns about replayable external messages, contract-balance drain from unguarded ACCEPT or SETGASLIMIT usage, predictable onchain randomness, execution of untrusted code, front-running, asynchronous cross-contract state assumptions, and unsafe code updates. The network relies on the Elector and Config contracts for validator elections, complaint handling, reward distribution, and proposal voting, and CertiK's formal-verification work on those same contracts uncovered two accounting-invariant violations. Bugs or misconfiguration in these surfaces could disrupt consensus, validator operations, or user funds. The Catchain 2.0 consensus upgrade activated on April 9, 2026 replaced core consensus timing assumptions, and newly deployed consensus code carries implementation risk until it accumulates an extended operating history. (Source: Security best practices in TON docs, System contracts in TON docs, CertiK formal verification of TON masterchain contracts, Unchained on Catchain 2.0)
The project has taken material security steps, including multiple audits by Trail of Bits, SlowMist, CertiK, and Zellic, formal verification of the masterchain contracts, a public bug bounty, and a Chainalysis incident-response retainer. These controls reduce risk but do not guarantee that every code exploit, bridge failure, validator fault, or operational incident will be prevented or detected in time. (Source: Security audits, CertiK formal verification of TON masterchain contracts, Chainalysis incident-response program)
The token model depends on continued validator participation, network usage, and demand for Telegram-linked applications, payments, and stablecoin settlement. Staking runs through single nominator, nominator pool, and liquid staking structures, and stablecoins are a major source of network liquidity, with USDt on TON available across more than 100 partner platforms and authorized USDt issuance on TON surpassing $1.43 billion by December 2024. The economics currently run thin relative to issuance. As of July 2026, daily fee burns of roughly 1,008 tokens stand against daily issuance that adds roughly 568,726 tokens net, so application volume would need to grow by an order of magnitude before the 50% fee-burn rule could outpace block rewards. Telegram's stewardship also concentrates demand assumptions on a single platform, so a shift in Telegram product strategy would directly affect gas demand, staking inflows, and token utility. If staking participation, payment demand, or ecosystem growth weakens, validator economics, liquidity, and token utility weaken with them. (Source: Staking overview in TON docs, Stablecoins on TON, USDt on TON on over 100 platforms, ETHNews on Gram issuance, CoinShares institutional research note)
Monetary policy and reward settings remain fully governance-controlled and have changed repeatedly. Holders and validators approved burning 50% of transaction fees, live since June 17, 2023. Validators voted in February 2023 to freeze 1,081,389,417 tokens in dormant mining wallets until February 21, 2027, and that unlock will return more than 20% of total supply to potential circulation in 2027. The Catchain 2.0 upgrade lifted issuance from roughly 0.6% toward a projected 3.6% annualized before mitigations, with net inflation running at approximately 1.37% as of July 2026, and validators took up a June 2026 proposal to cut block rewards to 0.35 tokens per masterchain block and 0.2 tokens per basechain block. Telegram's position as the largest validator gives it the single largest voice in these votes. Foundation incentive programs such as The Open League and the DeFi incentive program also direct large token flows. Changes in validator-voted parameters, incentive programs, or the frozen-supply unlock could change dilution, circulating supply, and user behavior in ways that are adverse to holders. (Source: TON holders and validators vote for the real-time burn, Coincu on the freeze vote, Coinpaper on the reward-cut proposal, ETHNews on Gram issuance, Our Crypto Talk on the validator takeover, The Open League Season 1)
This Token Transparency Filing is provided for general informational purposes only and does not verify or warrant the accuracy of individual answers.