Provide a concise narrative that clearly states each of (a)–(e) below.
GUNZ is a gaming Layer 1 blockchain that gives players verifiable ownership and free tradability of in-game items. The GUNZ Whitepaper states that there are currently no ecosystems in Web3 for true AAA games and that Gunzilla built GUNZ as the first AAA Web3 ecosystem, onboarding both Web3 and Web2 games. The chain supplies onchain infrastructure for a community driven market in in-game assets, anchored initially on the studio's own title Off The Grid, which is developed by Gunzilla Games and available in early access on the Epic Games Store, Steam, PlayStation, Xbox, and GeForce Now.
(Source: GUNZ Whitepaper, GUN Token Page, Off The Grid)
Gunzilla's disclosed operating priorities are scaling the GUNZ mainnet and migrating Off The Grid players from testnet infrastructure to mainnet, starting with a first cohort of 21,000 early adopters already on mainnet as of June 2025, with withdrawals of in-game item NFTs for early users scheduled to open in July 2025, and followed by the remaining 16.8 million player wallets. The Mainnet Migration Diaries dated 12 June 2025 state that the launch runs under the licence of the European crypto asset service provider Kauri Finance and that final revisions of a Virtual Asset Service Provider application to the Cayman Islands Monetary Authority were submitted after twelve months of due diligence, with the licence expected in the coming weeks. Gunzilla also expanded GUN to the Avalanche C-Chain and, on 10 July 2025, to Solana through LayerZero, and it ships a suite of white label products and SDKs covering P2P marketplaces, block explorers such as GunzScan, and token and NFT minting engines. The MiCAR white paper states that the Off The Grid full world release was planned for Q4 2025, and the game's full release is now scheduled for October 2026.
(Source: Mainnet Migration Diaries, Solana Expansion, GUNZ Whitepaper, GunzScan, MiCAR White Paper, Wikipedia Off The Grid)
GUNZ is an EVM compatible Layer 1 built as an Avalanche subnet with its own permissioned validator set and Snowman consensus. The whitepaper states that the network reaches sub second finality of about 0.8 seconds, supports a theoretical throughput above 4,500 transactions per second, applies no slashing, and requires validators to stake AVAX on the Avalanche primary network. Smart contract deployment is permissioned, so only approved addresses deploy code. The ecosystem includes in-game wallets, a peer to peer marketplace operated through the Virtual Asset Service Provider subsidiary Fireflies Island Limited, the GunzScan block explorer, and an NFT minting engine in which 10,000 Validator NFTs decode in-game items. The whitepaper reports more than 14 million active wallets, more than 440 million processed transactions, and a peak of over 900,000 daily active wallets, and it states that Off The Grid reached number one free to play on the Epic Games Store and won Game of the Year at the 2024 GAM3 Awards.
(Source: GUNZ Whitepaper, Avalanche Blog, GUNZ Documentation, GunzScan)
GUN is the gas currency of the GUNZ ecosystem and the primary in-game currency of Off The Grid. The whitepaper lists in-game spending on character and weapon customisations, base cosmetics, animations, weapons, accessories, and additional character or loadout slots, as well as the Off The Grid subscription and Battle Pass, HEX decoding fees, resale commissions, and other in-game fees. GUN also fuels Validator NFTs, which hold locked GUN that is burned each time the NFT mints an in-game item, and Validator NFT owners earn a resale commission of 1 to 5 percent by rarity. Gunzilla Games commits 30 percent of Off The Grid revenue to repurchasing GUN on the open market and redistributing it through the platform rewards fund.
(Source: GUNZ Whitepaper, MiCAR White Paper, GUN Token Page)
GUNZ runs a permissioned validator and smart contract environment. The documentation states that external validator nodes cannot join the network without approval and that only trusted partners and Ava Labs validator nodes participate. The MiCAR white paper states that GUN grants no rights to the holder beyond its utility functions, so tokenholders hold no vote over protocol policy, treasury decisions, validator membership, or issuer entities. Control rests with the issuer Poseidon 133 PTE. LTD., and Gunzilla has published no plan to hand any of these controls to tokenholders.
(Source: GUNZ Documentation, MiCAR White Paper, GUNZ Whitepaper)
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 |
|---|---|---|---|
Vladyslav Korolov (published elsewhere as Vlad Korolev) | Labs/DevCo | Co-founder and Chief Executive Officer, and director of Poseidon 133 PTE. LTD. (MiCAR White Paper) | Founder of PLINK, a matchmaking app for gamers with 20 million users, and co-founder of Blackwood Games, developer of Warface, which the whitepaper credits with more than 140 million users, 1.3 billion dollars of revenue, and 350 million dollars of EBITDA (GUNZ Whitepaper). |
Alexander Zoll | Labs/DevCo | Co-founder and Chief Strategy Officer, and director of Poseidon 133 PTE. LTD. (MiCAR White Paper) | Previously co-founder and Chief Executive Officer at Blackwood Games, the developer of Warface (GUNZ Whitepaper). |
Neill Blomkamp | Labs/DevCo | Co-founder and Chief Visionary Officer (MiCAR White Paper) | Oscar nominated director, screenwriter, producer, and visual effects artist whose films include District 9, Elysium, Chappie, and Gran Turismo (GUNZ Whitepaper). |
Timur Davidenko | Labs/DevCo | Chief Technology Officer (MiCAR White Paper) | Has 18 years of game development experience and was previously Technical Director on Warface, Far Cry, the Crysis franchise, and CryEngine (GUNZ Whitepaper). |
David Nicholson | Labs/DevCo | Executive Producer (MiCAR White Paper) | Held senior development and publishing roles at Psygnosis, Infogrames, Atari, Jagex, and Electronic Arts, and led the console team at Creative Assembly as Executive Producer on Halo Wars 2 and Hyenas (GUNZ Whitepaper). |
Dmitriy Markov | Labs/DevCo | Technical Director (MiCAR White Paper) | Worked at 4A Games as Lead Gameplay Developer and then Game Technical Director for 4A Engine on Metro Exodus, and contributed to Arktika.1 (GUNZ Whitepaper). |
Marina Danylyuk | Labs/DevCo | Chief Legal Officer (MiCAR White Paper) | Legal advisor for Swiss Blockchain Legal and co-founder of MiBit OU, a FinTech and blockchain consulting company (GUNZ Whitepaper). |
Christian Sullivan | Labs/DevCo | Operating Partner (GUNZ Whitepaper) | Seed investor in more than 10 unicorns including Yubico, Moonpig, Relativity Space, Astranis, Cruise, Republic, Rescale, and Retool, who worked on the United Financial Group trading desk and later backed more than 200 companies as an angel investor (GUNZ Whitepaper). |
Sven Schetzke | Labs/DevCo | Associate Product Director, Gunzilla GmbH (MiCAR White Paper) | The MiCAR white paper lists him among the persons involved in the project with a Frankfurt business address and discloses no prior experience (MiCAR White Paper). |
Enlai Chong | Labs/DevCo | Senior Corporate Lawyer, Poseidon 133 PTE. LTD. (MiCAR White Paper) | The MiCAR white paper lists him among the persons involved in the project with a Singapore business address and discloses no prior experience (MiCAR White Paper). |
Chan Wai Kwan | Labs/DevCo | Director, Poseidon 133 PTE. LTD. (MiCAR White Paper) | The MiCAR white paper names Chan Wai Kwan as a member of the issuer's management body and discloses no prior experience (MiCAR White Paper). |
Richard K. Morgan | Labs/DevCo | Script Writer (GUNZ Whitepaper) | Author of the novel Altered Carbon, later a Netflix series, and lead writer on Crysis 2 and the 2012 Syndicate reboot (GUNZ Whitepaper). |
Krasimir Nechevski | Labs/DevCo | Animation Director (GUNZ Whitepaper) | Previously Animation Director at Unity, where he directed the animation for the short film Adam (GUNZ Whitepaper). |
Nikolas Gekko | Labs/DevCo | Lead Art Director (GUNZ Whitepaper) | Shaped the visual style of AAA titles including Far Cry Primal, Call of Duty WWII, Halo Infinite, Destiny, and Battlefield 2042 (GUNZ Whitepaper). |
Volodymyr Savin | Labs/DevCo | Audio Director (GUNZ Whitepaper) | Created audio for the Cut the Rope mobile series and Metro Exodus and runs the virtual instrument company Strix Instruments (GUNZ Whitepaper). |
Kiran Pulicheri | Labs/DevCo | Technical Art Director (GUNZ Whitepaper) | Served as Tech Art Lead on AAA projects including Control, Death Stranding, and Marvel's Avengers over a career of more than 23 years (GUNZ Whitepaper). |
The GUNZ Foundation has published no officers. | Foundation | Gunzilla announced the GUNZ Foundation as a not-for-profit on 13 December 2024 but has named no president, executive director, or board (Decrypt GUNZ Foundation). | No officer biographies exist because no Foundation officers have been publicly identified (Decrypt GUNZ Foundation). |
Piers Kicks | Foundation | Expected member of the GUNZ Foundation advisory board, from Delphi Ventures (Decrypt GUNZ Foundation). | Decrypt reports that Delphi Ventures advised on the creation of the Foundation and that Piers Kicks was expected to join its advisory board (Decrypt GUNZ Foundation). |
No DAO exists for GUNZ. | DAO/Onchain Governance | GUNZ has no DAO and no onchain governance mechanism, so no governance office exists (MiCAR White Paper). | No DAO leadership exists because the MiCAR white paper states that GUN represents no contractual rights, claims, or ownership rights (MiCAR White Paper). |
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).
No DAO exists for GUNZ, so the DAO owns or controls no intellectual property. The MiCAR white paper describes Gunzilla as a brand operated by Poseidon 133 PTE. LTD. and attributes the Off The Grid asset to that company. The GUNZ documentation publishes no GUNZ chain source repository, and no repository, brand, or trademark is attributed to a DAO.
(Source: MiCAR White Paper, GUNZ Documentation)
No DAO holds contract or administrative powers over GUNZ. The chain is permissioned at two levels. Smart contract deployment requires address level approval, and validator set membership is restricted to approved trusted partners and Ava Labs validator nodes. Tokenholders hold no vote over either parameter, and no governance threshold, quorum, timelock, or onchain officeholder has been published for these powers.
(Source: GUNZ Whitepaper, GUNZ Documentation, MiCAR White Paper)
The only locked token construct in GUNZ is the Validator NFT. Each Validator NFT holds locked GUN that cannot be withdrawn and is burned during HEX decoding. The minting engine randomly selects Validator NFTs to decode HEXes into in-game NFTs, owners earn commissions in GUN and a share of resale proceeds from items they decode, and owners can deactivate the validator function to avoid selection. These rights are economic and confer no governance power.
(Source: GUNZ Whitepaper, MiCAR White Paper)
GUN accrues value through gas fee demand, in-game spending, HEX decoding fees, marketplace resale commissions, the Validator NFT burn, and the buyback funded by 30 percent of Off The Grid revenue. Holder rights stop there. The MiCAR white paper states that GUN is not offered to the public and carries no right of withdrawal, reimbursement, or refund, that GUN confers no purchaser rights beyond its utility, and that no investor compensation or deposit guarantee scheme covers it. Tokenholders hold no current right over revenue distribution or the treasury.
(Source: MiCAR White Paper, GUNZ Whitepaper)
No DAO exists for GUNZ, so no DAO dissolution mechanism, wind up procedure, or asset distribution authority exists. The MiCAR white paper names Singapore law as the governing law and the courts of Singapore as the competent forum for the issuer Poseidon 133 PTE. LTD.
(Source: MiCAR White Paper)
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 GUNZ Foundation is a not-for-profit entity announced on 13 December 2024 to oversee the GUN token and the GUNZ mainnet launch. Delphi Ventures advised on its creation. Gunzilla has not published the Foundation's jurisdiction of incorporation, registration number, or constitutional documents, and the MiCAR white paper names Poseidon 133 PTE. LTD., not the Foundation, as issuer, offeror, and the person seeking admission to trading.
(Source: Decrypt GUNZ Foundation, MiCAR White Paper)
The GUNZ Foundation owns no disclosed project intellectual property. The MiCAR white paper describes Gunzilla as a brand operated by Poseidon 133 PTE. LTD., and no repository, brand, domain, or subsidiary is attributed to the Foundation.
(Source: MiCAR White Paper, Decrypt GUNZ Foundation)
Gunzilla has published no charter, power schedule, or threshold mechanism granting the GUNZ Foundation authority over governance, treasury actions, protocol controlled resources, or token administration parameters, and no DAO exists for the Foundation to govern. The announced mandate is to oversee the GUN token and the mainnet launch. The whitepaper allocates 900,000,000 GUN to the Foundation for ecosystem expansion and infrastructure development but publishes no decision rule for its use.
(Source: Decrypt GUNZ Foundation, GUNZ Whitepaper, MiCAR White Paper)
The GUNZ Foundation holds no disclosed direct or indirect power over Poseidon 133 PTE. LTD. or Gunzilla GmbH. The MiCAR white paper names Poseidon 133 PTE. LTD. as issuer and offeror, records no parent company, and describes Gunzilla GmbH as fully owned by Poseidon 133 PTE. LTD., with no Foundation interest recorded.
(Source: MiCAR White Paper, Decrypt GUNZ Foundation)
The GUNZ Foundation holds no disclosed pause, upgrade, validator admission, or governance executor authority over the GUNZ chain or its contracts. The documentation describes validator admission and contract deployment approval as network level controls and does not assign them to the Foundation.
(Source: GUNZ Documentation, GUNZ Whitepaper)
The GUNZ Foundation receives 900,000,000 GUN, equal to 9 percent of total supply, subject to a 12 month cliff and 36 month vesting from the token generation event. Gunzilla has published no recurring revenue entitlement, fee share, or programmatic distribution policy directing protocol controlled resources to the Foundation beyond that allocation.
(Source: GUNZ Whitepaper, Tokenomist)
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.
Poseidon 133 PTE. LTD. is a Singapore company registered on 26 January 2015 under identifier 201502546D, with an address at 39 Robinson Road number 14-01 Robinson Point, Singapore 068911. The MiCAR white paper names it as issuer and offeror of GUN and the person seeking admission to trading, records no parent company, and describes Gunzilla as a brand it operates. Its management body comprises Vladyslav Korolov, Alexander Zoll, and Chan Wai Kwan. Gunzilla GmbH in Frankfurt am Main is a German company fully owned by Poseidon 133 PTE. LTD., founded in 2019 and employing more than 450 people. The whitepaper names Fireflies Island Limited as Gunzilla's Virtual Asset Service Provider subsidiary operating the peer to peer marketplace and describes Gunzilla Games as the company behind Off The Grid, GUNZ, and the gaming magazine Game Informer.
(Source: MiCAR White Paper, GUNZ Whitepaper)
The MiCAR white paper describes Gunzilla as a brand operated by Poseidon 133 PTE. LTD. and records the capitalisation of acquired intellectual property into the Off The Grid asset. No public trademark record was reviewed for this filing. The GUNZ chain source code is not published in a public repository, while the underlying Avalanche software is maintained by Ava Labs. Subsidiaries named in the public record are Gunzilla GmbH and Fireflies Island Limited.
(Source: MiCAR White Paper, GUNZ Documentation, GUNZ Whitepaper)
No DAO exists, so control rests with the operator. The network approves the addresses permitted to deploy smart contracts and admits validators to the set, and Gunzilla Games operates the buyback that returns 30 percent of Off The Grid revenue to the platform rewards fund. The whitepaper allocates 1,300,000,000 GUN to the Treasury and 1,000,000,000 GUN to Platform Rewards but publishes no named custodian, charter, or tokenholder check on those allocations.
(Source: GUNZ Whitepaper, GUNZ Documentation, MiCAR White Paper)
Gunzilla has published no governance agreement, service agreement, or shareholding disclosure formalising the relationship between Poseidon 133 PTE. LTD. and the GUNZ Foundation. Decrypt reports that Gunzilla announced the Foundation and that Delphi Ventures advised on its creation, and the MiCAR white paper records no Foundation control link.
(Source: Decrypt GUNZ Foundation, MiCAR White Paper)
The operator controls contract deployment and validator admission on GUNZ, since only approved addresses deploy code and only approved validators join the set. The mainnet player rollout was being conducted under the Kauri Finance crypto asset service provider licence as of June 2025, while the Cayman Islands Monetary Authority licence was pending, and GUN cannot be exported from in-game wallets. Gunzilla has published no multisig roster or signing threshold for the keys behind these powers.
(Source: GUNZ Whitepaper, GUNZ Documentation, Mainnet Migration Diaries, MiCAR White Paper)
The whitepaper allocates 1,300,000,000 GUN to Treasury, 1,000,000,000 GUN to Platform Rewards, 1,280,500,000 GUN to Founders and Team, and 529,000,000 GUN to Advisors. Revenue reaches Gunzilla through a 5 percent commission on player trades, HEX decoding fees, and an optional Off The Grid subscription priced at 11.99 dollars per month that passed 100,000 subscribers after the October 2024 launch. Gunzilla commits 30 percent of Off The Grid revenue to open market GUN buybacks for the platform rewards fund. The MiCAR white paper records a loss in each year from 2022 to 2024 and expected full cost coverage by revenue in 2025. In April 2026 former employees alleged unpaid wages, and two winding up petitions were filed against Gunzilla Games in the United Kingdom, one of which was ongoing as of April 2026. No dividend or cash distribution framework for equityholders has been published.
(Source: GUNZ Whitepaper, MiCAR White Paper, Game Developer Unpaid Pay Report, TheGamer Winding Up Report)
Disclose launch and initial supply details in a single initial allocation schedule covering the token's launch.
Total supply of GUN is 10,000,000,000 tokens, fixed at genesis. Initial circulating supply at the Binance listing on 31 March 2025 was 604,500,000 GUN, equal to 6.05 percent of total supply. The remaining 9,395,500,000 GUN launched locked under the schedules in part (f) or inside Validator NFTs.
(Source: Binance Launchpool Announcement, MiCAR White Paper, GUNZ Whitepaper)
(Source: GUNZ Whitepaper, MiCAR White Paper, Binance Launchpool Announcement, Tokenomist)
GUN launched without a public offering price. The MiCAR white paper states that GUN is not offered to the public and records the issue price as not applicable, while its summary states a listing price of 0.025. Distribution at launch ran through the 66th Binance Launchpool, where participants staked BNB, FDUSD, and USDC from 28 to 30 March 2025 to farm 400,000,000 GUN, and spot trading opened on Binance on 31 March 2025 at 1 PM UTC with price set by the market from that point.
(Source: MiCAR White Paper, Binance Launchpool Announcement, Binance Academy)
GUN. The token is native to the GUNZ Layer 1 and is also deployed on the Avalanche C-Chain at 0x26deBD39D5eD069770406FCa10A0E4f8d2c743eB and on Solana at 3jUf2RTyXp867piSB2dt8uUcNiLDW58asjGtXkRAkBbe.
(Source: GUN Token Page, Solana Expansion)
Total supply is fixed at 10,000,000,000 GUN, and the documentation states that the supply is distributed through vesting smart contracts. The MiCAR white paper states that the full supply was created at genesis with no further issuance. Two deflationary mechanisms run against that fixed cap. Validator NFTs burn a portion of their locked GUN each time they mint an in-game item, at a burn rate the whitepaper sets below the rewards Validator NFT owners earn. Gunzilla Games separately commits 30 percent of Off The Grid revenue to repurchasing GUN on the open market for redistribution through the platform rewards fund.
(Source: GUNZ Whitepaper, MiCAR White Paper, GUNZ Documentation)
Cliff and vesting periods run from the token generation event of 31 March 2025, and the whitepaper states that all sold tokens other than the KOL round stay locked through the first year. The Circulating Treatment column reflects status as of 28 September 2026. Tokenomist reported 3,514,081,175 GUN unlocked, equal to 35.14 percent of total supply, in data updated on 28 September 2026, with the next unlock scheduled for Advisors on 30 September 2026.
(Source: GUNZ Whitepaper, Tokenomist, Binance Launchpool Announcement)
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.
Planned airdrop
Not applicable. Gunzilla has announced no planned airdrop of GUN, so no recipient list commitment applies.
(Source: GUNZ Whitepaper, MiCAR White Paper)
Executed airdrop
Not applicable. Gunzilla has conducted no airdrop of GUN, so no per address allocation file, Merkle root, or claim contract exists.
(Source: Binance Launchpool Announcement, GUNZ Whitepaper)
No airdrop
Gunzilla has never conducted an airdrop of GUN to date and has announced no plan to execute one. Launch distribution to the public ran through the 66th Binance Launchpool, which allocated 400,000,000 GUN, equal to 4 percent of total supply, to users staking BNB, FDUSD, and USDC from 28 to 30 March 2025, with 320,000,000 GUN in the BNB pool and 40,000,000 GUN each in the FDUSD and USDC pools. Outside that programme, players obtain GUN by playing games on the GUNZ chain, buying GUN with cash through third party providers, or depositing GUN from external wallets and exchanges.
(Source: Binance Launchpool Announcement, Binance Academy, GUNZ Whitepaper)
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.
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.
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.").
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 prior incidents. No exploit affecting GUN, its supply, tokenholder balances, its token contracts or the Validator NFT mechanics is disclosed in the MiCAR white paper (June 2025) or the GUNZ whitepaper (March 2025), which are the issuer's most recent formal disclosures reviewed as of 2026-09-28.
(Source: MiCAR White Paper, GUNZ Whitepaper)
None. No exploit vector has been reported against the GUNZ network or the GUN token.
(Source: MiCAR White Paper)
None. No loss of funds, tokens, or in-game assets to an exploit has been reported.
(Source: MiCAR White Paper)
None required, because no incident occurred. The MiCAR white paper records that an audit was performed and describes a pentest and security analysis finding a strong security posture across the Gunzilla API and web platform, minor issues to be addressed, and a remediation plan in place for most findings.
(Source: MiCAR White Paper)
Not applicable, because no incident has been reported.
(Source: MiCAR White Paper)
None, because no incident has been reported and no post-mortem or advisory exists.
(Source: MiCAR White Paper)
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?
Impact of Regulatory Change on TGE and Listings
The token generation event and the Binance listing completed on 31 March 2025, so the main exposure now is continued listing. The MiCAR white paper names Italy as home Member State, lists 27 host Member States, and states that no competent authority has approved it. The whitepaper states that GUN is not a security under the US Securities Act of 1933 or the Howey Test, not a security based swap under the Commodity Exchange Act, and not a digital payment token under Singapore's Payment Services Act, and similar positions are taken for the Cayman Islands and Korea. Reclassification in any of those regimes would threaten exchange listings, custody, and wallet operations.
(Source: MiCAR White Paper, GUNZ Whitepaper, Binance Launchpool Announcement)
Entity-Level Regulatory Impact
Poseidon 133 PTE. LTD. is issuer, offeror, and the person seeking admission to trading, with Singapore law and courts governing. The mainnet player rollout was being conducted under the Kauri Finance licence as of June 2025, while a Cayman Islands Monetary Authority Virtual Asset Service Provider licence was pending. The peer to peer marketplace runs through Fireflies Island Limited with KYC required once deposits exceed 1,000 dollars per account per month. In April 2026 former staff alleged unpaid wages and one of two UK winding up petitions against Gunzilla Games was ongoing, which raises enforcement and continuity risk for the operating group.
(Source: MiCAR White Paper, Mainnet Migration Diaries, GUNZ Whitepaper, Game Developer Unpaid Pay Report, TheGamer Winding Up Report)
Tokenholder Tax Treatment
Gunzilla publishes no tax guidance for GUN. The MiCAR white paper states that no investor compensation scheme under Directive 97/9/EC and no deposit guarantee scheme under Directive 2014/49/EU covers GUN. Tax treatment of in-game spending, Validator NFT commissions, resale proceeds, and trading gains is uncertain and differs by jurisdiction, and tokenholders are responsible for understanding their own tax obligations.
(Source: MiCAR White Paper)
Jurisdictional & User Access Restrictions
GUN is not offered to US persons and has not been registered or approved as a security, capital markets product, or digital payment token in any jurisdiction. The MiCAR white paper states that GUN cannot be transferred into the game from sanctioned wallets and that regional restrictions apply to users from sanctioned countries. GUN cannot be exported from in-game wallets, which the whitepaper attributes to compliance with major gaming platforms, so players can only convert GUN into in-game assets and withdraw those. A change in a user's location or compliance status can cost access or transferability.
(Source: Solana Expansion, MiCAR White Paper, GUNZ Whitepaper)
Bugs and Design Flaws
GUNZ depends on a permissioned Avalanche subnet running Snowman consensus with no slashing, a LayerZero bridge to Solana, an Avalanche C-Chain token deployment, custodial player wallets, and the Validator NFT decoding engine. The MiCAR white paper lists technology risks including private key management, settlement finality, scaling limits, network attacks, consensus failures or forks, bugs in core code, smart contract security, dependency on underlying technology, data corruption, and third party risk. A failure in any of these could halt gas payment, item minting, bridging, or wallet access, and gameplay depends on the chain for all of them.
(Source: MiCAR White Paper, GUNZ Whitepaper, Solana Expansion, Avalanche Blog)
Security Measures & Their Limitations
The MiCAR white paper records that an audit was performed and summarises a pentest and security analysis of the Gunzilla API and web platform that found a strong security posture, minor issues, and a remediation plan for most findings. It links to the Ava Labs audit repository, which covers Avalanche software but does not mention GUNZ. No public audit report for the GUNZ chain contracts, no formal verification, and no bug bounty scope were found, and the MiCAR white paper records mitigation measures as not applicable. The GunzScan explorer displays testnet data. A test of the API and web platform leaves consensus, bridge, custody, and Validator NFT failure modes outside its scope.
(Source: MiCAR White Paper, Ava Labs Audits, GunzScan)
Critical Economic Assumptions
The design assumes sustained Off The Grid demand. GUN utility depends on in-game spending, HEX decoding volume that drives both Validator NFT income and the burn, marketplace resale commissions of 1 to 5 percent, gas demand, and Off The Grid revenue that funds the 30 percent buyback. Validator rewards approximate 30 percent of Off The Grid fiat revenue, so validator economics move with the game. On 28 September 2026 the CoinGecko API showed GUN at about 0.003 dollars, roughly 97 percent below its 0.115 dollar all time high, which signals how far these assumptions have been tested. Weaker player activity would reduce fees, burn, buyback size, and Validator NFT yield together.
(Source: GUNZ Whitepaper, CoinGecko API GUNZ)
Governance Control over Monetary Policy & Rewards
Tokenholders have no governance control. Supply is fixed at 10,000,000,000 GUN, but tokenholders hold no vote on reward flows, treasury policy, fee parameters, buyback size, burn rate, or validator economics, which the operator sets. Private A, Private B, Advisors, Treasury, Foundation, and Team allocations remain on schedules running to around 2029, and Tokenomist showed 35.14 percent of supply unlocked on 28 September 2026. The MiCAR white paper records a loss in each year from 2022 to 2024, and April 2026 reports of unpaid wages add funding risk for the operator that controls incentive design.
(Source: MiCAR White Paper, GUNZ Whitepaper, Tokenomist, Game Developer Unpaid Pay Report)
This Token Transparency Filing is provided for general informational purposes only and does not verify or warrant the accuracy of individual answers.
