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
Ondo addresses the accessibility gaps and fragmented infrastructure of traditional finance by issuing institutional-grade financial products on public blockchains. Ondo tokenizes real-world assets such as US Treasuries and publicly traded equities to improve market transparency, composability, and accessibility while connecting offchain value to onchain markets.
(Source: Ondo's Journey)
Ondo supports ongoing development and operations through two arms. Affiliated issuers manage tokenized securities, including USDY, OUSG, and the Ondo Stocks tokenized equities suite, and a software development arm builds onchain protocols and infrastructure. The Ondo Foundation, through its subsidiaries, holds a 99% common equity interest in the historical USDY issuer and uses proceeds from USDY growth in furtherance of its mission. Ondo Finance Inc. provides tokenization services to, and is an equityholder of, Ondo Global Markets (BVI) Limited. Current priorities include expanding the Ondo Stocks platform of 100 plus tokenized US stocks and ETFs, building regulated US market access through the completed acquisition of Oasis Pro and its SEC-registered broker-dealer, ATS, and transfer agent licenses, and offering tokens to EU and EEA retail investors under a base prospectus approved by the Financial Market Authority Liechtenstein.
(Source: Ondo's Journey, Unlock Proposal, Important Notes, Oasis Pro Completion)
Ondo operates two business lines. The first issues and manages tokenized securities. USDY is a yield-bearing token providing economic exposure to short-term US Treasuries and is issued by Ondo Global Markets (BVI) Limited, a British Virgin Islands business company. OUSG is a tokenized US Treasury fund issued by Ondo I LP, a Delaware limited partnership. Ondo Stocks are structured notes issued by Ondo Global Markets (BVI) Limited that provide economic exposure to more than 100 tokenized US stocks and ETFs. The second business line develops onchain protocols and infrastructure, including Flux Finance, a lending protocol governed by the Ondo DAO that supports tokenized securities as collateral.
(Source: Important Notes, Legal & Regulatory, Unlock Proposal)
ONDO is the governance token for the Ondo DAO and Flux Finance. Voting power is based on ONDO ownership, holders can delegate voting power to other wallets, and proposal submission requires 100,000,000 ONDO of voting power held directly or by delegation. The DAO is a fork of Compound's Governor Bravo and uses Tally to manage onchain voting. ONDO confers no rights to revenue, dividends, or yield.
(Source: ONDO Token Docs, Ondo DAO Docs, Flux Governance Docs)
ONDO holders exercise control over the protocol, including economic parameters and smart contract upgrades, through onchain governance proposals. The DAO may elect committees or multisigs to manage certain processes, such as updating economic parameters or pausing the protocol in critical times. The DAO can also choose a new admin, manage a treasury of assets, control ONDO emissions, and call arbitrary functions. Governance proposals move from an optional forum discussion on the Flux Finance Governance Forum to a binding onchain vote executed after a timelock delay.
(Source: Ondo DAO Docs, Flux Governance Docs, Unlock Proposal)
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 |
|---|---|---|---|
Ian De Bode | Labs / DevCo | Chief Executive Officer, named by the company on May 25, 2026. His removal is the subject of pending litigation described below. | De Bode led McKinsey & Company's digital assets practice before joining Ondo as Chief Strategy Officer in 2023. He was promoted to President of Ondo Finance in November 2025 and led strategy, product, and day-to-day operations for more than two years before being named CEO. CoinDesk |
Nathan Allman | Labs / DevCo | Founder and former Chief Executive Officer. Allman died unexpectedly in May 2026 at age 32. | |
Justin Schmidt | Labs / DevCo | Announced as President and COO in March 2023. Ian De Bode assumed the President title in November 2025. Ondo has not publicly disclosed Schmidt's current role. | Schmidt has more than 19 years of financial services experience, served as Head of Digital Assets at Goldman Sachs where he led the firm's digital asset strategy, served as Head of Strategy at Talos, worked as a quantitative equities portfolio manager for hedge funds in New York and London, and graduated from MIT with computer science degrees focused on artificial intelligence and decentralized applications. Justin Announcement |
Chris Tyrrell | Labs / DevCo | Announced as Chief Risk and Compliance Officer. | Tyrrell previously served as Head of Digital Assets Compliance and Head of Data Management Risk at Goldman Sachs, as Americas Chief Compliance Officer at Blockchain.com, and as Chief Compliance Officer at EDX Markets. Risk & Compliance Announcement |
Peter Curley | Labs / DevCo | Head of Global Regulatory Affairs, announced September 2025. | Curley previously served as Senior Policy Advisor at Coinbase, Senior Advisor on Financial Institutions Policy at the US Department of the Treasury, Associate Director at the US Securities and Exchange Commission, and Head of Strategy and Head of IPO Supervision at Hong Kong Exchanges & Clearing Ltd. Peter Curley Announcement |
Patrick McHenry | Labs / DevCo | Vice Chairman of the advisory board, announced February 2025. | McHenry served in the US Congress from 2005 to January 2025, chaired the House Financial Services Committee from 2023 to 2025, served as Speaker Pro Tempore of the House in 2023, and holds advisory roles at Stripe and Andreessen Horowitz. The Block |
Control of Ondo Finance Inc. is contested. Delaware Court of Chancery filings state that Nathan Allman died while serving as Ondo Finance's CEO, sole director, and controlling shareholder. Kathleen Allman, his mother, was appointed personal representative of his estate on June 26, 2026, expanded the board, and at a July 24, 2026 board meeting voted to remove De Bode from all company positions while appointing herself chair and interim CEO. The estate's lawsuit asks the Delaware Court of Chancery to determine who lawfully controls the company. The litigation is pending as of August 21, 2026. | Labs / DevCo | ||
The Ondo Foundation has not publicly disclosed the names of its directors or officers. | Foundation | The Ondo Foundation has not publicly disclosed official titles for its leadership. | The Ondo Foundation has not publicly disclosed leadership biographies. Foundation Intro |
The Ondo DAO does not have a named leadership roster. Governance is exercised directly by ONDO holders and their delegates through forum discussion and onchain voting on Tally. Ondo DAO Docs | DAO / Onchain Governance | The Ondo DAO does not assign official leadership titles. | The Ondo DAO does not publish leadership biographies. |
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
The Ondo DAO deployed and governs the Flux Finance protocol, a fork of Compound's Governor Bravo and lending contracts. The DAO has not publicly disclosed ownership of any code repositories, trademarks, or brands. The Ondo Foundation's published mandate includes acquiring and handling IP rights for the ecosystem.
(Source: Unlock Proposal, Ondo DAO Docs, Foundation Intro)
ONDO holders exercise control over the protocol, including economic parameters and smart contract upgrades, through onchain governance proposals. With respect to Flux Finance, the DAO can list new fToken markets, pause fToken markets, update the interest rate model per market, update the oracle address, and withdraw the reserve of an fToken market. The DAO can additionally choose a new admin, manage a treasury of assets, control ONDO emissions, and call any arbitrary function. Proposal submission requires 100,000,000 ONDO of voting power held directly or by delegation. Proposals proceed from an optional forum post to a binding onchain vote on Tally, pass only if quorum is met, and execute after a timelock delay. The DAO may elect committees or multisigs to manage certain processes, such as updating economic parameters or pausing the protocol in critical times.
(Source: Ondo DAO Docs, Flux Governance Docs, Unlock Proposal)
No locking or staking mechanism grants additional governance rights. Voting power is based solely on ONDO ownership and delegation. Tokens that remain locked under the Global Lock-Up vesting schedule retain full voting rights in the DAO.
(Source: ONDO Token Docs, Ondo DAO Docs)
ONDO holders hold governance rights only. No adopted mechanism directs protocol revenue, fees, or distributions to ONDO holders. The Ondo DAO manages a treasury of assets and controls ONDO emissions, and ONDO holders direct both through onchain governance proposals.
(Source: Unlock Proposal, ONDO Token Docs)
Neither the Ondo DAO nor the Ondo Foundation has publicly disclosed who can dissolve or wind up the DAO or the mechanism for doing so.
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 Ondo Foundation is a Cayman Islands Foundation Company and a nonprofit with no beneficial owners. Ondo Finance helped establish the Foundation in 2022, and the Foundation was formerly known as the Neptune Foundation. CoinList sale materials from 2022 identified the Neptune Development Foundation, a Cayman Islands foundation company, as the ultimate parent of Nami Industries Limited, the seller in the ONDO Community Access Sale.
(Source: Foundation Intro, Unlock Proposal, CoinList Sale Page)
The Foundation's published mandate includes acquiring and handling IP rights, issuing governance tokens, deploying protocol smart contracts, and hosting web applications for certain ecosystem platforms. The Foundation has not published a schedule of specific code repositories or trademarks it owns. Its disclosed subsidiaries include Flux Finance Inc., a wholly owned subsidiary that owns 90.01% of Ondo Global Markets (BVI) Limited, the issuer of Ondo tokenized stocks and USDY. The Foundation, through its subsidiaries, also owns 99% of the common equity in Ondo USDY LLC, the original issuer of USDY.
(Source: Foundation Intro, Legal & Regulatory, Unlock Proposal)
The Foundation acquired ONDO token issuance rights from Ondo Finance as its first act after formation. Its mandate includes treasury management, issuing governance tokens, deploying protocol smart contracts, web application management, and strategic partnerships. Under FIP-08, the Foundation was responsible for choosing the exact Public Launch date for ONDO transferability, and it selected January 18, 2024. The Foundation has not publicly disclosed voting thresholds or other formal methods by which it can direct DAO governance or token administration beyond these roles.
(Source: Unlock Proposal, Foundation Intro, FIP-08, ONDO Token Docs)
The Foundation is independently governed and holds no disclosed ownership or control rights over Ondo Finance Inc. The Foundation works with Ondo Finance as a commercial partner focused on the provision of certain technology and business development services and the management of certain tokenized RWAs. Neither entity has publicly disclosed any mechanism by which the Foundation can direct decision-making at Ondo Finance Inc.
(Source: Unlock Proposal)
The Foundation's mandate includes deploying protocol smart contracts and issuing governance tokens. The Foundation has not publicly disclosed pause roles, upgrade roles, multisig configurations, or the thresholds attached to any administrative authority it holds.
(Source: Foundation Intro)
The Foundation, through its subsidiaries, owns 99% of the common equity in Ondo USDY LLC and benefits from the growth of USDY, using proceeds from that growth in furtherance of its mission. Through its wholly owned subsidiary Flux Finance Inc., the Foundation holds 90.01% of Ondo Global Markets (BVI) Limited, the current issuer of Ondo tokenized stocks and USDY. No governance-approved mechanism directs Ondo DAO treasury assets, protocol fees, or ONDO token distributions to the Foundation, its contributors, or other participants.
(Source: Unlock Proposal, Legal & Regulatory)
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
The primary DevCo is Ondo Finance Inc., a Delaware (USA) corporation founded in 2021. Delaware Court of Chancery filings state that founder Nathan Allman served as the company's CEO, sole director, and controlling shareholder until his death in May 2026, and control of the company is contested in litigation that Allman's estate filed against Ian De Bode and Ondo Finance Inc. in the Delaware Court of Chancery on July 24, 2026. As of 2026-10-06 the case remains pending with no ruling on control, and De Bode remains CEO and a director under a September 3, 2026 court order (CoinDesk Succession Dispute).
(Source: Important Notes, Unlock Proposal, CoinDesk Control Dispute)
Ondo Finance Inc. has not published a schedule of the code repositories, trademarks, or other IP it owns. Its disclosed subsidiaries and affiliates include Ondo I GP LLC, the general partner of Ondo I LP, Ondo Capital Management LLC, an SEC-registered investment adviser, and the Oasis Pro entities acquired in October 2025, which hold an SEC-registered broker-dealer, an SEC-registered alternative trading system, and an SEC-registered transfer agent. Ondo Finance Inc. also holds a 9.99% equity interest in Ondo Global Markets (BVI) Limited.
(Source: Trust & Security, OUSG Page, Oasis Pro Completion, Legal & Regulatory)
Ondo Finance Inc. holds no administrative or contractual power over the Ondo DAO, the DAO treasury, or ONDO token administration, but parties tied to the company hold DAO voting power. The Protocol Development allocation of 3,300,000,000 ONDO went to core contributors such as Ondo Finance and the Private Sales allocation of 1,290,246,044 ONDO went to investors in Ondo Finance equity rounds, and ONDO that remains locked under the Global Lock-Up retains full voting rights in the DAO (ONDO Token). Nathan Allman's estate holds a large ONDO position that includes locked tokens, and control of the company is the subject of the litigation described in item (a) (CoinDesk Succession Dispute). The company transferred ONDO token issuance rights to the Ondo Foundation in 2022. Ondo Finance Inc. provides tokenization services to, and holds a 9.99% equity interest in, Ondo Global Markets (BVI) Limited, and it is the sole member of both Ondo I GP LLC, the general partner of the Fund that issues OUSG, and Ondo Capital Management LLC, the Fund's investment adviser. Ondo Global Markets (BVI) Limited has engaged Ondo Finance solely as a service provider for tokenization and general and administrative operations and maintains full segregation of assets, accounting, and operations from Ondo Finance and the Ondo Foundation group.
(Source: Unlock Proposal, Important Notes, OUSG Page, GM Trust & Transparency)
Ondo Finance Inc. holds no disclosed control rights over the Ondo Foundation. The Foundation is independently governed, is a nonprofit with no beneficial owners, and works with Ondo Finance as a commercial partner for technology and business development services. Ondo Finance helped establish the Foundation in 2022.
(Source: Unlock Proposal, Foundation Intro)
Ondo Finance took guardian-role admin actions on legacy Ondo V1 vault contracts in October 2021 and kept certain admin functions of that deprecated system behind a 3/5 multisig. Ondo Finance Inc. has not publicly disclosed an admin authority map, pause roles, upgrade roles, or multisig thresholds for the current ONDO governance and issuance stack.
(Source: Admin Actions Post)
Ondo Finance Inc. raised $4 million in a seed equity round led by Pantera Capital in August 2021 and $20 million in a Series A financing co-led by Founders Fund and Pantera Capital in April 2022, for $24 million in total equity financing. The company earns revenue by providing tokenization services to Ondo Global Markets (BVI) Limited, in which it holds a 9.99% equity interest, and through its wholly owned subsidiaries Ondo I GP LLC and Ondo Capital Management LLC, which serve as general partner and investment adviser to the Fund that issues OUSG. No governance-approved mechanism directs Ondo DAO treasury assets or ONDO token distributions to Ondo Finance Inc. or its equityholders. The Protocol Development allocation of 3,300,000,000 ONDO (33.0% of supply) is allocated to core contributors focused on building infrastructure, products, and protocols to expand the Ondo ecosystem, such as Ondo Finance, and is subject to the Global Lock-Up release schedule.
(Source: Seed Round Coverage, Series A Announcement, Important Notes, OUSG Page, Unlock Proposal)
Disclose launch and initial supply details in a single initial allocation schedule covering the token's launch.
Response
The full supply of 10,000,000,000 ONDO was issued at launch. All ONDO tokens were subject to a Global Lock-Up until the Ondo DAO approved FIP-08 and the tokens became transferable at the Public Launch on January 18, 2024. The initial circulating supply at Public Launch was 1,426,647,567 ONDO, approximately 14.3% of total supply, and the remaining 8,573,352,433 ONDO, more than 85% of total supply, remained locked at launch.
(Source: FIP-08, ONDO Token Docs, Unlock Proposal)
ONDO was allocated across four categories. Ecosystem Growth received 5,210,869,545 ONDO (52.1%) for growth incentives such as airdrops and for contributors to the Ondo ecosystem, including developers, educators, researchers, and strategic contributors. Protocol Development received 3,300,000,000 ONDO (33.0%) for core contributors focused on building infrastructure, products, and protocols to expand the Ondo ecosystem, such as Ondo Finance. Private Sales received 1,290,246,044 ONDO (12.9%), representing two closed historical funding rounds to strategic contributors who invested in Ondo Finance equity rounds. The Community Access Sale received 198,884,411 ONDO (2.0%), sold on CoinList in May 2022 to over 18,000 early community members. The full schedule appears in the table below.
(Source: FIP-08)
The Community Access Sale on CoinList had a fixed main sale price of $0.055 per token and a private option priced at $0.03 per token for long-term supporters of Ondo and CoinList users with high Karma thresholds. The sale began May 12, 2022 at 17:00 UTC. No other allocation category carried a public offering price. Private Sales tokens were attached to two equity funding rounds rather than sold at a published token price.
(Source: CoinList Sale Page, CoinList Sale Announcement Post, FIP-08)
The ticker is ONDO. The token contract address is 0xfAbA6f8e4a5E8Ab82F62fe7C39859FA577269BE3 on Ethereum.
(Source: ONDO Token Docs)
The total supply is 10,000,000,000 ONDO. The supply is fixed with no scheduled or planned inflation.
(Source: ONDO Token Docs, FIP-08)
All allocation categories were subject to the Global Lock-Up, released by DAO vote under FIP-08 at the January 18, 2024 Public Launch. Community Access Sale participants were released entirely from the Global Lock-Up at Public Launch, with approximately 90% of their 199M tokens freely transferable immediately and the remainder releasing over the following 12 months under CoinList tranche terms. Ecosystem Growth unlocked 24% of its bucket (1.25B ONDO) at Public Launch, with the remaining 3.96B ONDO unlocking in stages 12, 24, 36, 48, and 60 months after Public Launch. Protocol Development and Private Sales remained fully locked for at least 12 months after Public Launch with release over the following four years, five years total. Seed and Series A investors carry a 1-year lock plus 48-month release, and Ondo core team members are bound by a 5-year lockup.
(Source: FIP-08, Unlock Proposal, ONDO Token Docs)
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
This sub-item does not apply. Ondo has not announced a planned ONDO token airdrop with defined target segments or an allocation method.
(Source: FIP-08)
Executed airdrop
This sub-item does not apply. Ondo has never executed an ONDO token airdrop, and no per-address ONDO airdrop allocation file, Merkle dump, Dune table, or claim endpoint exists.
No airdrop planned or conducted
This sub-item applies. Ondo has never conducted an ONDO token airdrop to date, and the ONDO TGE did not include an airdrop. Initial distribution occurred through the Community Access Sale on CoinList and the allocation schedule adopted under FIP-08.
Supplemental Notes
The Ecosystem Growth allocation of 5,210,869,545 ONDO is set aside for growth incentives such as airdrops, but no ONDO airdrop has been scheduled or announced under that allocation. The Ondo Foundation operates the Ondo Points program, launched in January 2024, which targets ONDO holders and delegators, governance participants, Flux stablecoin lenders, USDY holders, minters, and liquidity providers, OUSG holders, mUSD holders, Galxe participants, and users of Ondo assets across DeFi. The Foundation took a snapshot of eligible wallets on April 1, 2026 after several campaigns closed. Wallets with 100 or more Ondo Points can claim a USDC reward of 50 to 500 USDC depending on which of ten point-balance tranches their address falls into, plus 100 raffle tickets, and wallets below 100 points can claim raffle tickets equal to their point balance. Points program rewards are denominated in USDC and raffle tickets, not ONDO, so the program is not an ONDO airdrop.
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
Neither Ondo Finance Inc., the Ondo Foundation, nor the Ondo DAO has publicly disclosed any market-making agreement, token loan, or token allocation to a market maker for the ONDO token. No native ONDO tokens are publicly disclosed as loaned or allocated to market makers.
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
ONDO trades on major centralized exchanges, and the listings were announced by the exchanges themselves. Neither Ondo Finance Inc., the Ondo Foundation, nor the Ondo DAO has publicly disclosed any listing agreement terms, token allocations committed for listings, listing lockups, or listing fees paid in ONDO for any exchange.
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
Ondo conducted two equity fundraising rounds with associated token allocations and one public token sale. The Private Sales token bucket of 1,290,246,044 ONDO (12.9% of supply) represents the two closed equity funding rounds. No material OTC token sales or discounted market-maker sales have been publicly disclosed.
(Source: FIP-08, ONDO Token Docs)
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
One prior incident affected a deprecated Ondo V1 product. No exploit has affected the ONDO token, the Ondo DAO treasury, Flux Finance, or Ondo's current tokenized asset products as of August 21, 2026.
Describe material risk factors across the three categories below. Each category includes prompts to address at a minimum.
(a) Regulatory, Legal & Tax Risks — Describe how evolving laws and regulations could affect the project by answering, at a minimum, questions like:
Impact of Regulatory Change on TGE and Listings: (If applicable) How could evolving or conflicting laws and regulations affect your ability to complete the TGE, deliver tokens to purchasers, and list or maintain the token on trading venues in key jurisdictions?
Entity-Level Regulatory Impact: (If applicable) How could regulatory or legal changes impact your core entities (Foundation, DevCo, DAO, affiliated service providers), including enforcement actions, licensing requirements, or forced changes to structure or operations?
Tokenholder Tax Treatment: (If applicable) What uncertainties exist around how tokenholders may be taxed, and make clear that tokenholders are responsible for understanding their own tax obligations?
Jurisdictional & User Access Restrictions: (If applicable) If the project restricts access for certain jurisdictions or user types (e.g., U.S. persons, sanctioned countries, retail vs. professional), what are those restrictions and what risks do they create for users and for the project?
(b) Protocol, Technology & Security Risks — Describe risks to network and contract reliability, correctness, and safety by answering, at a minimum, questions like:
Bugs and Design Flaws: (If applicable) What bugs, design flaws, or implementation errors could exist in your core protocol code, smart contracts, and any bridges, rollups, or oracles that you depend on, and how could these lead to loss of funds or disruption of the protocol?
Security Measures & Their Limitations: (If applicable) What security measures have you taken (audits, formal verification, bug bounties), and what types of failures might these measures still fail to detect or prevent?
(c) Token Economics, Unlocks & Incentive Risks — Describe how the token's economic design and supply schedule could affect holders by answering, at a minimum, questions like:
Critical Economic Assumptions: (If applicable) Which economic assumptions (e.g., staking yields, fee revenue, liquidity incentives, MEV capture, demand for blockspace) are critical for protocol security, utility, and governance, and what happens if those assumptions fail?
This Token Transparency Filing is provided for general informational purposes only and does not verify or warrant the accuracy of individual answers.
(Source: Introducing Ondo Points, Snapshot Taken, FIP-08)
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
Ondo's product tokens carry securities-law restrictions. Ondo Stocks and USDY tokens have not been registered under the US Securities Act of 1933 or the securities or financial instrument laws of other jurisdictions and may not be offered or sold in the United States or to US persons unless registered or exempt. Ondo Global Markets (BVI) Limited offers and sells its tokens in reliance on Regulation S. In the United Kingdom, Switzerland, and for certain tokens the EEA, Ondo Stocks and USDY are offered only to qualified investors or professional clients, while certain tokens are offered to both professional and retail investors in the EEA under a base prospectus approved by the Financial Market Authority Liechtenstein on November 11, 2025. OUSG is limited to accredited investors and qualified purchasers. Changes to securities-law interpretation or exemption availability would constrain offering, sale, and transferability of these products under the restrictions described in the issuer's legal materials. The 2022 ONDO Community Access Sale excluded residents and citizens of the United States, China, South Korea, Canada, and other unsupported jurisdictions.
(Source: Important Notes, Legal & Regulatory, QQQon Final Terms, CoinList Sale Announcement Post)
At the entity level, Ondo carries regulatory dependencies across multiple issuers and licensed subsidiaries. Ondo Stocks and USDY are issued by Ondo Global Markets (BVI) Limited, a bankruptcy-remote BVI special purpose vehicle that is 90.01% owned by Flux Finance Inc., a wholly owned Ondo Foundation subsidiary, and 9.99% owned by Ondo Finance Inc. OUSG is issued by Ondo I LP, whose general partner and investment adviser are wholly owned by Ondo Finance Inc. Ondo completed its acquisition of Oasis Pro in October 2025, adding an SEC-registered broker-dealer, alternative trading system, and transfer agent, and Oasis Pro Markets secured FINRA authorizations in 2026 to offer tokenized equities and funds to US investors. The SEC closed a multi-year confidential investigation into Ondo in late November 2025 without charges, as Ondo announced on December 8, 2025. The probe had examined whether Ondo's tokenization complied with federal securities laws and whether ONDO was a security. A separate corporate control dispute is pending. Following founder Nathan Allman's death in May 2026, his estate filed suit in the Delaware Court of Chancery seeking to remove Ian De Bode and asking the court to determine who lawfully controls Ondo Finance Inc. Adverse outcomes in that litigation, changes in licensing requirements, or renewed enforcement activity could force changes to entity structure or operations.
(Source: Legal & Regulatory, Important Notes, Oasis Pro Completion, FINRA Authorizations, The Block SEC Closure, CoinDesk Control Dispute)
Ondo has not published tax guidance specific to ONDO tokenholders, and tax treatment of ONDO varies by jurisdiction. Each tokenholder is responsible for understanding and fulfilling that holder's own tax obligations, and Ondo's product disclosures state that investors are responsible for conducting their own research, verification, and consultation for professional advice.
(Source: Important Notes)
Ondo has experienced one concrete smart-contract design failure. In October 2021, an audited SushiStakingv2Strategy contract for deprecated Ondo V1 vaults contained a swap-direction bug that required guardian-role admin actions and manual remediation, with no loss of customer funds. This incident demonstrates that audited code can still contain implementation errors. Ondo's current stack carries additional design and operational risk surfaces. The Ondo Global Markets Solana program uses attestation-based mint and redemption verification, role-based access control, token-level and user-level rate limits, and Pyth oracle price validation, so access-control mistakes, oracle failures, or attestation errors in those components could impair minting, redemption, or transfers. Ondo Stocks and USDY depend on offchain custodial and broker-dealer relationships, so operational failures at service providers could disrupt product function even without a smart contract exploit.
(Source: Admin Actions Post, GM Solana Repository, GM Trust & Transparency)
Ondo maintains significant but inherently limited security measures. Ondo's audit index lists more than twenty independent reviews, including a February 2026 Cantina audit, a December 2025 Zellic audit of the Global Markets Solana program, multiple 2025 Cantina and FYEO audits, a July 2025 Cyfrin audit, and earlier Spearbit, Halborn, Code4rena, Zokyo, NetherMind, ABDK, Quantstamp, Peckshield, and Certik reviews. Ondo runs a bug bounty program on Immunefi paying rewards in USDC of up to $1,000,000 for critical smart contract vulnerabilities. For Ondo Global Markets, Ankura Trust Company serves as Verification Agent and Security Agent, reviews and verifies the existence and amounts of the underlying securities daily, confirms reconciliation of investor liabilities and fund reserves, and holds a first-priority security interest in the underlying collateral for tokenholders. OUSG receives third-party fund administration from NAV Consulting and an annual audit. These measures reduce but cannot eliminate the risk of future implementation bugs, governance or key-management mistakes, oracle failures, or disruptions introduced by later code and operational changes.
(Source: Audits Index, Zellic Publications, Immunefi Bug Bounty, GM Trust & Transparency, Trust & Security)
ONDO has a fixed 10 billion supply with no scheduled or planned inflation, and its economic risk is concentrated in the unlock schedule and its governance-only utility. As of August 21, 2026, the circulating supply is 4,869,330,647 ONDO, 48.7% of total supply, with the remainder locked and releasing on the FIP-08 schedule at 12, 24, 36, 48, and 60 months after the January 18, 2024 Public Launch, extending into 2029. The January 18, 2026 unlock released approximately $780 million of ONDO across protocol development, ecosystem growth, and private sale allocations, and the next major unlock is scheduled for January 2027. ONDO confers governance rights without revenue, dividend, or yield rights, so the token's value depends on demand for governance participation and expectations for the Ondo ecosystem. Concentrated future unlocks, weaker ecosystem growth than expected, or reduced demand for ONDO governance would pressure liquidity conditions, governance participation, and tokenholder price exposure.
(Source: ONDO Token Docs, FIP-08, CoinMarketCap ONDO, Tokenomist ONDO, Unlock Weekly Coverage)
Governance can materially change protocol economics. The Ondo DAO controls ONDO emissions to grow use of Ondo DAO products, can update the interest rate model per Flux market, can list or pause fToken markets, can update the oracle address, can withdraw fToken market reserves, manages a treasury of assets, can choose a new admin, and can call arbitrary functions through onchain proposals. The DAO may also elect committees or multisigs for parameter updates or protocol pauses. Adverse governance decisions on emissions, collateral settings, interest-rate models, or treasury deployment would change user incentives and the token's governance value proposition, and the 100,000,000 ONDO proposal threshold concentrates proposal power in large holders and delegates.
(Source: Unlock Proposal, Ondo DAO Docs, Flux Governance Docs)
