Question
Provide a concise narrative that clearly states each of (a)–(e) below.
Response
Onyx is a modular Layer 3 blockchain built for financial-grade applications, targeting decentralized finance, payment systems, governance frameworks, and other blockchain-based services that require institutional-grade throughput and low transaction costs.
(Source: About Onyx, Onyx Protocol)
Current operational priorities include continued development and maintenance of the Onyx Layer 3 Ledger and the Goliath Layer 1 chain (announced March 2025 for financial institutions), governance-driven emissions and treasury allocations, security hardening through audits and a bug bounty program, and support for ecosystem products including Onyx AI, the Onyx Smart Wallet, and Chain-linked infrastructure services such as Sequence.
(Source: Utility & Governance, Governance Overview, , , )
Onyx operates the XCN Ledger, an EVM-compatible Layer 3 network deployed on the Arbitrum Orbit stack and settled through Coinbase's Base network. XCN is native to Ethereum and is extended to Base, BNB Chain, and the Onyx Ledger through bridge mechanics under which one XCN is locked on Ethereum and one is made available or minted on the destination network. A second chain, Goliath, is a standalone Layer 1 targeting banks and financial institutions using asynchronous Byzantine Fault Tolerance consensus.
(Source: About Onyx, Token Bridge)
XCN serves four primary functions. First, it is the gas token for transactions on the Onyx Ledger, with a portion of transaction fees burned onchain. Second, it is the governance token used through staking-based voting and proposal rights in Onyx DAO governance on Ethereum. Third, it is used for service payments and premium or discounted access across products including Onyx Cloud and Sequence ledger services. Fourth, XCN is used for validator staking within the network.
Protocol control currently relies on staking-based governance on Ethereum with a proposal threshold of 100,000,000 XCN, a three-day voting period, a 200,000,000 XCN support threshold for proposal success, and a two-day timelock before execution. A Guardian Wallet retains the authority to cancel proposals before execution, meaning the control surface is not purely token-majoritarian. In March 2026, the DAO's guardians exercised a 5/5 multisig veto to reject non-OIP polls, reset governance state, and raise the poll-creation minimum to 10,000,000 XCN.
(Source: Governance Overview, Governor, Onyx DAO Guardians Exercise Multi-Sig Authority to Veto Recent Polls)
Question
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 |
|---|---|---|---|
Deepak Thapliyal | Labs / DevCo | Chief Executive Officer of Chain | No prior-experience disclosure found in public sources. |
Mike Herron | Labs / DevCo | Inaugural Chief Marketing Officer of Chain | Veteran marketer with more than two decades of experience across U.S. Cellular, Lukka, Solo Cup, United Airlines, and other Fortune 500 campaigns. |
Labs / DevCo | |||
The public team surface is organized around Chain, the DevCo. No separate public Foundation team roster or named DAO leadership roster exists for XCN. | Labs / DevCo | ||
No named Foundation personnel have been identified in the public record. The foundation was formed through governance proposal CIP-007 in January 2023, but no named leadership roster has been publicly disclosed. | Foundation | ||
No named DAO or onchain-governance leadership roster exists in the public record. Governance rights are held by XCN stakers collectively through on-chain smart contracts. | DAO / Onchain Governance |
Question
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
Onyx operates an on-chain DAO governance layer through staking-based voting on Ethereum. No DAO legal wrapper or dissolution process has been publicly identified.
(Source: Governance Overview, Governor, Utility & Governance, MiCA Crypto-Asset White Paper)
The public record does not disclose what IP the Onyx DAO owns or controls, including codebases, repositories, or trademarks.
Governance is controlled by the Onyx DAO through decentralized smart contracts voted on by XCN stakers on Ethereum. Submitting a proposal requires 100,000,000 XCN in voting weight. The voting period runs three days measured in Ethereum blocks. A proposal requires majority approval and at least 200,000,000 XCN in supporting votes before being queued in a two-day timelock. The Guardian can immediately cancel any unexecuted proposal, and any address may cancel a proposal if the proposer's balance falls below the proposal threshold. In October 2025, OIP-62 passed and established a multisig DAO and DAO Registry while increasing the native staking rate. In March 2026, the DAO's guardians used a 5/5 multisig veto to reject non-OIP polls, reset governance state to the established framework, and raise the poll-creation minimum to 10,000,000 XCN.
(Source: Governance Overview, Governor, Voting Period, Cancel, OIP-62 is now live!, Onyx DAO Guardians Exercise Multi-Sig Authority to Veto Recent Polls)
Users must stake XCN to obtain voting rights. Voting weight is proportional to staked XCN balance. Stakers can propose and vote on protocol changes, emissions, and treasury allocations. Stakers earn periodic staking rewards; following execution of OIP-62, a community report in the governance forum stated that staking was earning above 35% at that time.
(Source: Governance Overview, Utility & Governance, OIP-62 is now live!)
The MiCA disclosure states that XCN does not represent ownership, equity, debt, profit-sharing rights, dividends, interest, or repayment claims against the issuer or any other entity. XCN stakers can propose and vote on treasury allocations and emissions through governance, but no contractual right to protocol revenue or distributions exists.
(Source: MiCA Crypto-Asset White Paper, Utility & Governance)
The public record does not identify who can dissolve the Onyx DAO or by what mechanism.
Question
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
A foundation exists. Through governance proposal CIP-007 in January 2023, 15 billion XCN were donated to a newly formed non-profit foundation concurrent with the renaming of Chain Protocol to Onyx Protocol. The foundation's formal legal name and jurisdiction of incorporation have not been publicly disclosed in the sources reviewed.
(Source: About XCN, MiCA Crypto-Asset White Paper)
A non-profit foundation was formed via governance proposal CIP-007 in January 2023 and received 15 billion XCN at formation. Its formal legal name and jurisdiction of incorporation are not publicly disclosed.
The public record does not disclose what IP the foundation owns or controls, including codebases, repositories, or trademarks, nor does it identify any subsidiary entities under the foundation.
The public record does not disclose whether the foundation holds any formal powers over DAO governance, treasury actions, protocol-controlled resources, or token administration parameters.
The public record does not disclose whether the foundation holds any direct or indirect influence over Chain's decision-making.
The public record does not identify any pause, upgrade, or governance-executor authorities held by the foundation.
The foundation received 15 billion XCN through the CIP-007 governance vote in January 2023. The public record does not disclose any ongoing programmatic, contractual, or governance-approved mechanism directing protocol-controlled resources, treasury assets, fees, revenue, or token distributions to the foundation beyond the initial allocation.
(Source: MiCA Crypto-Asset White Paper)
Question
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
Chain is the DevCo. Its own legal disclaimer states that XCN tokens were issued and distributed by Chain, a corporation located in Saint Kitts and Nevis. Chain acquired a licensed European crypto provider that became Chain Europe UAB, adding a subsidiary operating entity in Europe.
(Source: About Chain, Chain Token – sequence.chain.com, Chain Announces Acquisition of Licensed Crypto Company in Europe and Launch of Chain Prime)
Chain is a corporation incorporated in Saint Kitts and Nevis. Chain Europe UAB is a subsidiary operating entity that became part of Chain following Chain's acquisition of a licensed European crypto provider.
(Source: Chain Token – sequence.chain.com, Chain Announces Acquisition of Licensed Crypto Company in Europe and Launch of Chain Prime)
The public record does not disclose what IP Chain owns or controls, including specific codebases, repositories, or trademarks.
The public record does not disclose whether Chain holds any formal powers over Onyx DAO governance, treasury actions, protocol-controlled resources, or token administration parameters.
The public record does not disclose whether Chain holds any direct or indirect influence over the foundation's decision-making.
The public record does not identify any pause, upgrade, or governance-executor authorities held by Chain.
Chain has raised over $40 million in corporate funding from investors including Nasdaq, Citigroup, Visa, Capital One, Fiserv, Orange, Khosla Ventures, RRE Ventures, Thrive Capital, and SV Angel. The public record does not disclose any currently operative programmatic, contractual, or governance-approved mechanism directing protocol-controlled resources, treasury assets, fees, revenue, or token distributions to Chain or its equityholders.
(Source: About Chain)
Question
Disclose launch and initial supply details in a single initial allocation schedule covering the token's launch.
Response
The CHN token launched in November 2021 after a CertiK audit with a maximum supply of 100,000,000 CHN (pre-redenomination). At launch, 50% of supply was allocated to Sequence users through a retroactive distribution to all customers from non-OFAC-listed countries. Any CHN not claimed and transferred to a wallet before March 1, 2022 was burned, eliminating approximately 30% of total supply. The token was then redenominated at a ratio of 1:1,000, creating XCN. The on-chain XCN contract defines an INITIAL_SUPPLY of 21,537,311,000 XCN, which the constructor minted to msg.sender at deployment. In January 2023, CIP-007 passed, burning 5 billion XCN and transferring 15 billion XCN to the newly formed non-profit foundation, reducing total supply from approximately 53 billion to approximately 48 billion. The current coded MAX_SUPPLY in the contract is 68,895,442,185 XCN; the live token-supply page states a fixed max supply of 68,892,071,756 XCN — a minor discrepancy between the contract source and the published figure that the issuer has not publicly reconciled.
(Source: XCN Token Contract Source, Token Supply, Chain Token – sequence.chain.com)
The pre-redenomination CHN/XCN distribution comprised the following buckets based on the original Chain token documentation and subsequent governance actions:
(Source: Token Supply, Token Distribution, Chain Token – sequence.chain.com)
XCN was not offered at a fixed offering price. When XCN entered the market in mid-March 2022 following the CHN-to-XCN redenomination, the token's opening market price was approximately $0.05, reaching a peak of $0.1161 on April 19, 2022. No fixed TGE price was set.
(Source: Capital.com XCN Price History)
XCN.
(Source: About XCN, Onyx Protocol)
XCN is a capped token with an active burn mechanism. The live token-supply page states a fixed maximum supply of 68,892,071,756 XCN, with 20,489,639,348 XCN burned on Ethereum and a current total supply of 48,402,437,326 XCN as of August 18, 2025. The on-chain contract defines MAX_SUPPLY as 68,895,442,185 XCN, a minor discrepancy from the published figure. Transaction fees on the Onyx Ledger are partially burned, creating ongoing deflationary pressure. Supply is not fixed in the sense of zero further issuance — ongoing Timelock and DAO releases add to circulating supply — but the protocol does not permit minting beyond the coded maximum.
(Source: Token Supply, XCN Token Contract Source, About XCN, Utility & Governance)
Two locked pools remain active as of August 18, 2025:
(Source: Token Distribution)
Question
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
XCN was not distributed through a traditional airdrop. The original CHN token distribution in November 2021 was a retroactive distribution to existing Sequence product customers, not a public airdrop. No subsequent airdrop to the general public has been conducted, and no public airdrop program is identified in the official record.
(Source: About XCN, Token Distribution, Token Supply, Chain Token – sequence.chain.com)
Question
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
As of August 18, 2025, the official token-supply disclosure states that zero XCN is loaned to any third parties for market making or other arrangements. The project has not disclosed any named market maker, term duration, or agreement structure beyond that statement.
(Source: Token Supply)
Question
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
The official XCN exchanges page identifies spot, perpetual-futures, and DEX venue listings as of June 25, 2025. The MiCA disclosure states that the issuer does not control, operate, or maintain any trading platform and that listings occur at venue discretion. Governance proposal OIP-57 to provide XCN/USDT liquidity on PancakeSwap for the BNB Chain Phase 1 passed and was queued on June 23, 2025; a community update on July 8, 2025 confirmed that liquidity had been added. Token allocations committed, term durations, and native-token listing fees for individual venues are not publicly disclosed.
(Source: XCN Exchanges, MiCA Crypto-Asset White Paper, OIP-57 to Provide $XCN Liquidity for @BNBCHAIN Phase 1 has successfully passed)
Question
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
The public record does not provide a complete schedule of XCN token-sale instruments, token counts sold, or vesting schedules. Two surfaces are publicly documented:
First, Chain has raised over $40 million in corporate funding from investors including Nasdaq, Citigroup, Visa, Capital One, Fiserv, Orange, Khosla Ventures, RRE Ventures, Thrive Capital, and SV Angel. This is a corporate equity raise, not a token sale instrument.
Second, following the November 2023 exploit, a governance proposal described a previously announced $40 million XCN token facility involving LDA Capital and others, proposed as a treasury-sale facility to fund user reimbursement. A subsequent governance update confirmed that the DAO never used that facility and lost access to it as of December 12, 2023.
The MiCA disclosure states that it does not relate to any new token issuance or fundraising activity.
(Source: About Chain, Recovery Proposal 1 of 3: Allocate funds from the DAO Treasury, Onyx DAO Token Facility Update, MiCA Crypto-Asset White Paper)
Question
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
The Onyx Protocol suffered an exploit affecting the oPEPE lending market on its protocol. The governance proposal documenting the incident was posted on November 3, 2023.
(Source: Recovery Proposal 1 of 3: Allocate funds from the DAO Treasury)
The exploit was caused by a rounding implementation bug in the oPEPE market's smart contract code.
(Source: Recovery Proposal 1 of 3: Allocate funds from the DAO Treasury)
The exploit caused an approximately $2.1 million protocol loss to the lending markets. XCN staking contracts and Uniswap liquidity pools were not affected.
(Source: Recovery Proposal 1 of 3: Allocate funds from the DAO Treasury)
The DAO engaged security partners, reported the hacker to law enforcement, proposed using a previously announced $40 million XCN token facility to compensate affected users, and halted developer and DAO salaries pending improved security practices established with the community.
(Source: Recovery Proposal 1 of 3: Allocate funds from the DAO Treasury)
The DAO lost access to the $40 million token facility as of December 12, 2023 and had not used it prior to that date. The public record does not contain a post-mortem disclosing a final reimbursement ledger or a confirmed resolution of affected-user compensation.
(Source: Onyx DAO Token Facility Update)
(Source: Recovery Proposal 1 of 3: Allocate funds from the DAO Treasury, Onyx DAO Token Facility Update)
Question
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?
Question
Identify to the best of your ability the token's current deployments across chains, including project-issued deployments, project-endorsed representations, and, if possible, documented third-party wrapped or bridged representations.
For each entry, provide:
Multiple entries on the same chain are permitted.
Definition: A protocol-level asset is an asset whose balances and transfers are handled directly by the blockchain's core rules, rather than by a token smart contract. For protocol-level assets without a token contract address, enter "No contract address" and identify the asset and chain.
Response
Token Contract Address or Onchain Asset Identifier | Chain | Deployment Type | Project Relationship | Supporting Source |
|---|---|---|---|---|
0xa2cd3d43c775978a96bdbf12d733d5a1ed94fb18 | Ethereum | Direct token issuance | native-token |
This Token Transparency Filing is provided for general informational purposes only and does not verify or warrant the accuracy of individual answers.
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
The regulatory environment for crypto-assets is evolving across the EU, the U.S., and other jurisdictions, and future legal changes could alter XCN's legal classification, compliance obligations, disclosure standards, and market-access requirements. Exchange listings and service-provider access are subject to AML, CTF, KYC, sanctions, and other regulatory filters, and certain jurisdictions prohibit or restrict the use of decentralized networks or self-custody.
Tokenholders are responsible for complying with all legal, tax, and regulatory obligations in their own jurisdictions. The issuer does not provide tax advice, and tax treatment of XCN acquisitions, staking rewards, governance rewards, or disposals varies by jurisdiction.
Regulatory changes could affect the issuer (Chain, incorporated in Saint Kitts and Nevis), Chain Europe UAB, affiliated service providers, exchanges, custodians, and other ecosystem partners through investigations, fines, changing compliance requirements, and reduced market access.
The Onyx interface terms state that the interface is hosted by Onyx DAO on GitHub, is directed to persons and entities located within the United States or the United Kingdom, and bars users located in sanctioned jurisdictions or whose use would be illegal under applicable law. Disputes are routed to LCIA arbitration in London, United Kingdom.
(Source: MiCA Crypto-Asset White Paper, Terms of Service)
The Onyx stack includes a Governor, Timelock, XCN Staking contract, DAO Registry, AdminProxy, L3UpgradeExecutor, bridge contracts, and token gateways deployed across Ethereum, Base, BNB Chain, and the Onyx Ledger. Bugs in governance, upgradeability, bridging, or rollup infrastructure could affect both protocol control and user-facing operations. Failures in connected networks, bridges, wallets, custodians, explorers, and other third-party infrastructure could disrupt network operations, transferability, or user access.
Onyx experienced a confirmed exploit in November 2023: a rounding bug in the oPEPE market caused approximately $2.1 million in losses to lending market participants. Security measures in place include independent audits, formal verification, a bug bounty program, a governance timelock, and a Guardian cancellation layer. These measures reduce but do not eliminate risk, and the bug bounty documentation explicitly states that the protocol operates on evolving technology that may still contain undiscovered vulnerabilities.
(Source: About Onyx, Smart Contracts, Token Bridge, Bug Bounty, MiCA Crypto-Asset White Paper, Recovery Proposal 1 of 3: Allocate funds from the DAO Treasury, Onyx Protocol Bug Bounty, Governance Overview)
XCN utility depends on continued demand for blockspace, governance participation, staking participation, and service usage across Onyx products. If transaction demand, staking participation, or ecosystem usage decline materially, the network faces weaker governance participation, reduced staking alignment, lower fee burn, and reduced funding flexibility for ongoing operations.
As of August 18, 2025, 11,000,000,146 XCN remained locked in the Timelock Contract and 2,636,239,565 XCN remained locked in the DAO Contract. The Timelock releases 200,000,000 XCN every 30 days through March 1, 2030. The DAO Contract allows up to 200,000,000 XCN per month with rollover of unused capacity. These scheduled and governance-discretionary releases represent ongoing supply additions that create potential sell pressure, particularly if market demand does not absorb issuance at equivalent rate.
The on-chain contract defines MAX_SUPPLY as 68,895,442,185 XCN while the live token-supply page states 68,892,071,756 XCN — a discrepancy between contract source and published documentation that the issuer has not publicly reconciled. The proposed 2023 XCN token facility with LDA Capital and others was never executed, but that episode demonstrates that treasury-liquidity actions — even when not consummated — can affect perceived supply risk.
(Source: Token Supply, Token Distribution, XCN Token Contract Source, Recovery Proposal 1 of 3: Allocate funds from the DAO Treasury, Onyx DAO Token Facility Update, MiCA Crypto-Asset White Paper, About XCN, Utility & Governance)