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Origintrail

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Origintrail Disclosures

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B1 v1.1·Filed 12 Oct 2026Partial - 7 gaps

Contents

  1. Project & Team
  2. 01Description of Project
  3. 02Known Project Team
  4. 03DAO Structure
  5. 04Primary Foundation
  6. 05Primary Dev Co
  7. Token Supply & Allocations
  8. 06Initial Allocation
  9. 07Airdrop Process
  10. Transactions & Market Structures
  11. 08Market Maker Agreements & Deals
  12. 09CEX / DEX Agreements & Deals
  13. Financial Disclosures & Risks
  14. 10Prior Token Sales & Fundraising
  15. 11Previous Exploits Affecting The Native Token
  16. 12Material Risk Factors (Regulation, Technology, Token Economics)

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.

Project & Team

01Description of Project

Provide a concise narrative that clearly states each of (a)–(e) below.

  • (a) Problem the project solves — The problem the project is solving.
  • (b) Operational priorities — Provide a high-level description of how the project expects to support ongoing development and operations over time.
  • (c) High-level project overview — How the project works at a high level.
  • (d) Primary token functions — The primary functions of the token (e.g. gov participation).
  • (e) Control surface reliance — If any, briefly describe the anticipated or possible evolution of the protocol's governance/control model.

Response

(a) Problem the project solves

Organizations and AI systems rely on data that is scattered across separate databases and is hard to verify. OriginTrail runs a Decentralized Knowledge Graph (DKG) where data is published as Knowledge Assets anchored onchain, so anyone can check where a piece of information came from and whether it has been changed. The project began in supply chain traceability and now focuses on verifiable knowledge for AI agents.

(Source: OriginTrail Docs, OriginTrail Ecosystem White Paper 2.0)

(b) Operational priorities

Trace Labs, the for-profit core development company, funds OriginTrail development from a treasury that an undated community guide puts at over 100 million TRAC; no current treasury figure is published. Trace Labs also sells nOS, an enterprise AI agent operating system built on the DKG.

(Source: Trace Labs, OriginTrail and TRAC, Blockscout, TracToken Contract, Trace Labs)

(c) High-level project overview

DKG V10 runs on Base and Gnosis, where each deployment has a Hub contract that registers the protocol's staking, publishing and Knowledge Asset contracts. TRAC is an ERC-20 token issued on Ethereum and bridged to Base through Superbridge, to Gnosis through OmniBridge and to NeuroWeb, a Polkadot parachain, through Snowbridge.

(Source: Contract Addresses, Bridging TRAC, Conviction and Economics)

(d) Primary token functions

TRAC is the utility token of the OriginTrail network. The V10 terms define it as the token used to pay for onchain publication, updates and verification quorum submissions and to secure the network through staking. Stakers lock TRAC behind node operators in Staking Conviction positions, and publishers can commit TRAC in Publisher Conviction accounts for publishing discounts.

(Source: DKG V10 Terms and Conditions, TRAC Token, Staking and Migration)

(e) Control surface reliance

Protocol changes are proposed through the public OT-RFC process, where core developers move a proposal from Draft to Accepted to Final. The V10 Hub owner on Base is a 2-of-3 MultiSigWallet, and new staking lock tiers are added only through that Hub owner. The protocol treasury fee is governance-set and stays at 0% until wider consensus is reached, and no tokenholder voting process for it has been published. NeuroWeb uses its own native token, NEURO, for gas.

(Source: Whitepaper and RFCs, Blockscout, Base Hub Owner, Pre-Mainnet Bug Bounty, Staking and Migration, Bridging TRAC)

02Known Project Team

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

Tomaž Levak

Labs/DevCo

Founder and Managing Director of Trace Labs, Director of Trace Labs Ltd. and director of OriginTrail, digitalne rešitve za dobavne verige, d.o.o. (IQ.wiki, Trace Labs, Trace Labs Terms and Conditions, OriginTrail Terms and Conditions)

Levak studied International Relations (BA, 2007 to 2012) and Human Resources Management (MA, 2012 to 2014) at the University of Ljubljana, worked as a marketing advisor on the EKODAR organic meat traceability project at KZ Šaleška dolina in 2011 and advised the organising committee of the Kuwait Shooting Federation in 2013 (IQ.wiki, Tomaž Levak).

Žiga Drev

Labs/DevCo

Founder and Managing Director of Trace Labs (IQ.wiki, Trace Labs)

Drev holds a BA in International Relations and studied for an MBA at the University of Ljubljana, co-founded Trace Labs in 2013 while finishing his MBA and in 2017 helped design a blockchain food traceability blueprint that made OriginTrail an inaugural member of the Walmart Food Innovation Pipeline (IQ.wiki, Žiga Drev).

Branimir Rakić

Labs/DevCo

Founder and CTO of Trace Labs (IQ.wiki, Trace Labs)

Rakić studied for an MSc in Electrical and Computer Engineering at the University of Belgrade and worked as a freelance web developer, as a network testing engineer at P3 Communications from 2011 to 2013 and as a web department lecturer at SAE Institute until 2014 (IQ.wiki, Branimir Rakić).

Jurij Škornik

Labs/DevCo

General Manager of Trace Labs (IQ.wiki, Trace Labs)

The reviewed profile names Škornik's role and does not list his earlier positions (IQ.wiki, Trace Labs).

No token-issuing foundation exists for TRAC, and Trace Alliance z.b.o., the Slovenian association that owns the OriginTrail Academy, names no officers in its published terms (Academy Terms).

Foundation

No foundation officer titles exist because TRAC was issued without a foundation (Academy Terms, Blockscout, TracToken Contract).

No foundation officers are named, so there is no prior experience to report.

No DAO governs TRAC, and the V10 Hub on Base is owned by a 2-of-3 MultiSigWallet whose three signer addresses are not publicly attributed to named people (Blockscout, Base Hub Owner, Contract Addresses).

DAO/Onchain Governance

The multisig signers hold no published titles, and the docs refer to the role as a multisig (ICustodian) with a timelock (Pre-Mainnet Bug Bounty).

No DAO officeholders or signers are named, so there is no prior experience to report.

03DAO Structure

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).

  • (a) IP ownership & control — State what IP the DAO owns or controls (e.g., codebases/repos, trademarks/brands). Note any license if relevant.
  • (b) Contract/admin powers — List onchain or administrative authorities and limits: pause/upgrade roles (e.g., multisig pause), governance-executor authorities, and the method of authority for each (e.g., veto, majority, super-majority).
  • (c) Locked-token rights (conditional) — If locking/staking for additional rights exists, explain the additional rights and what tokenholders can and cannot decide. If no locking mechanism exists, leave absent.
  • (d) Value accrual & holder rights — If any, describe the current rights of tokenholders over revenue distribution and the treasury.
  • (e) Dissolution authority — State who can dissolve/wind up the DAO and by what mechanism (e.g., onchain vote threshold, board resolution of a legal wrapper).

Response

(a) IP ownership & control

No DAO exists for TRAC, so no DAO owns IP. The V10 terms name OriginTrail, digitalne rešitve za dobavne verige, d.o.o. as the licensor of the node software under the Apache License 2.0 and reserve the OriginTrail trademarks. The code is published in the OriginTrail GitHub organization.

(Source: DKG V10 Terms and Conditions, GitHub OriginTrail/dkg)

(b) Contract/admin powers

No DAO holds contract or admin powers. The TRAC contract on Ethereum has no pause, burn or upgrade function, and minting was permanently finished. The admin powers that do exist sit with the 2-of-3 MultiSigWallet that owns the V10 Hub, which can register replacement contracts and add staking tiers. That multisig is not a tokenholder-controlled body.

(Source: Blockscout, TracToken Contract, Blockscout, Base Hub Owner, Pre-Mainnet Bug Bounty)

(c) Locked-token rights (conditional)

TRAC can be locked in V10 Staking Conviction positions, which are ERC-721 NFTs. Lock tiers of 1, 3, 6 and 12 months raise a position's reward weight to 1.5x, 2x, 3.5x and 6x, and the multiplier does not mint or burn principal. Locking gives a larger share of staking rewards. Locked tiers have no early exit.

(Source: Staking and Migration, Conviction and Economics)

(d) Value accrual & holder rights

TRAC holders have no right to revenue distribution or to direct any treasury. Stakers earn TRAC that publishers pay for publishing, updates and lifetime extensions, and any protocol treasury fee is taken from that staker-bound amount. The treasury fee has a default of 3% and a cap of 10%, and it stays at 0% until governance sets a recipient. The V10 terms state that rewards are programmatic and not owed.

(Source: Conviction and Economics, Staking and Migration, DKG V10 Terms and Conditions)

(e) Dissolution authority

No DAO or DAO legal wrapper exists, so no party holds authority to dissolve one. The OriginTrail docs, the V10 terms and the Trace Labs legal pages describe no DAO and no wind-down mechanism.

(Source: DKG V10 Terms and Conditions, Trace Labs Terms and Conditions)

04Primary Foundation

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.

  • (a) Entity — Type and jurisdiction.
  • (b) IP ownership & control — What IP the entity owns/controls (repos/code, trademarks/brand; license optional) and an explanation of any subsidiary entities.
  • (c) Powers over DAO, treasury, protocol-controlled resources, and token administration — If any, describe the current powers over DAO governance, treasury actions, protocol-controlled resources (e.g. revenue), token administration, or reward parameters, and the method/threshold for each.
  • (d) Powers over DevCo — Explain whether the foundation can exert direct or indirect influence over decision-making of the DevCo.
  • (e) Contract/admin powers — Pause/upgrade/governance-executor authorities and the method/threshold for each (e.g., veto/majority/super-majority; "3/5 multisig").
  • (f) Current economic arrangements and distribution policies — Describe any current governance-approved, contractual, or programmatic mechanisms, if any, by which protocol-controlled resources, treasury assets, fees, revenue, rewards, or token distributions may be directed to this entity, its equityholders, contributors, or other participants. If no such mechanism currently exists, state that explicitly. Do not discuss hypothetical future dividends, repurchases, or distributions unless formally adopted.

Response

(a) Entity

No primary Foundation exists. TRAC was issued in January 2018 through a token contract whose sale and allocation wallets were controlled by the team, and no foundation took part in the issuance. Trace Alliance z.b.o., company registration number 8749914000, at Vojkova cesta 63 in Ljubljana, Slovenia, owns the OriginTrail Academy site, and it played no disclosed role in issuing TRAC.

(Source: Academy Terms, Blockscout, TracToken Contract, Trace Labs, OriginTrail and TRAC)

(b) IP ownership & control

Not applicable because no primary Foundation exists. The node software licence and trademarks sit with OriginTrail, digitalne rešitve za dobavne verige, d.o.o., as described in Section 5.

(Source: DKG V10 Terms and Conditions)

(c) Powers over DAO, treasury, protocol-controlled resources, and token administration

Not applicable because no primary Foundation exists. No foundation address holds any role in the TRAC contract or the V10 Hub.

(Source: Blockscout, TracToken Contract, Blockscout, Base Hub Owner)

(d) Powers over DevCo

Not applicable because no primary Foundation exists, so no foundation can influence Trace Labs.

(Source: Trace Labs, OriginTrail and TRAC)

(e) Contract/admin powers

Not applicable because no primary Foundation exists. The only live admin role over V10 contracts is the 2-of-3 Hub owner multisig described in Section 5(e).

(Source: Blockscout, Base Hub Owner)

(f) Current economic arrangements and distribution policies

Not applicable because no primary Foundation exists. No fee, treasury or token flow is directed to a foundation, and the protocol treasury fee stays at 0% with no recipient set.

(Source: Conviction and Economics, Staking and Migration)

05Primary Dev Co

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.

  • (a) Entity — Type and jurisdiction.
  • (b) IP ownership & control — What IP the entity owns/controls (repos/code, trademarks/brand; license optional) and an explanation of any subsidiary entities.
  • (c) Powers over DAO, treasury, protocol-controlled resources, and token administration — If any, describe the current powers over DAO governance, treasury actions, protocol-controlled resources (e.g. revenue), token administration, or reward parameters, and the method/threshold for each.
  • (d) Powers over Foundation — Explain whether the DevCo can exert direct or indirect influence over decision-making of the Foundation.
  • (e) Contract/admin powers — Pause/upgrade/governance-executor authorities and the method/threshold for each (e.g., veto/majority/super-majority; "3/5 multisig").
  • (f) Current economic arrangements and distribution policies — Describe any current governance-approved, contractual, or programmatic mechanisms, if any, by which protocol-controlled resources, treasury assets, fees, revenue, rewards, or token distributions may be directed to this entity, its equityholders, contributors, or other participants. If no such mechanism currently exists, state that explicitly. Do not discuss hypothetical future dividends, repurchases, or distributions unless formally adopted.

Response

(a) Entity

Trace Labs Ltd. is the primary DevCo, a Hong Kong company at Wyndham Street 46-48 with Tomaž Levak as Director. It is the for-profit core development team of OriginTrail and ran the January 2018 TRAC sale. OriginTrail, digitalne rešitve za dobavne verige, d.o.o., a Slovenian limited liability company at Vojkova cesta 63 in Ljubljana with Levak as director, operates origintrail.io, and the V10 terms state that it developed OriginTrail V10.

(Source: Trace Labs Terms and Conditions, Trace Labs Privacy Policy, OriginTrail Terms and Conditions, DKG V10 Terms and Conditions, What is OriginTrail (TRAC))

(b) IP ownership & control

OriginTrail, digitalne rešitve za dobavne verige, d.o.o. is the named licensor of the V10 node software, which is released under the Apache License 2.0, and the terms forbid use of the OriginTrail trademarks without permission. The source code is public in the OriginTrail GitHub organization. The terms also state that OriginTrail does not own or control the V10 network. The Slovenian business register lists OriginTrail d.o.o. (registration number 8088314000, registered November 10, 2017) as owned 50% by Žiga Drev and 50% by Tomaž Levak, both directors, so Trace Labs Ltd. holds no shares in it; the link between the two companies is Levak as co-owner and director of both (CompanyWall, OriginTrail d.o.o., fetched 2026-10-06).

(Source: DKG V10 Terms and Conditions, GitHub OriginTrail/dkg, Trace Labs Terms and Conditions, OriginTrail Terms and Conditions)

(c) Powers over DAO, treasury, protocol-controlled resources, and token administration

No DAO exists for Trace Labs to control. Trace Labs controls the development treasury, which an undated community guide puts at over 100 million TRAC, and the token contract minted the 100,000,000 TRAC future development allocation to a team multisig wallet at launch. That multisig (0x20e2ab81e11d4d02fe71b8cf9e8e3c9e2f714d5e) later moved its TRAC to externally owned addresses and held under 1 TRAC as of 2026-10-06, and no current treasury balance or address is published (Blockscout, Team Multisig Wallet). No spending rule or threshold for this treasury is published.

(Source: Trace Labs, OriginTrail and TRAC, Blockscout, TracToken Contract, Blockscout, Base Hub Owner)

(d) Powers over Foundation

No primary Foundation exists, so Trace Labs holds no power over one. Trace Alliance z.b.o. shares the Vojkova cesta 63 address with OriginTrail d.o.o., and no control relationship between them is published.

(Source: Academy Terms, OriginTrail Terms and Conditions)

(e) Contract/admin powers

The TRAC token contract on Ethereum, verified as TracToken, has finished minting permanently, so the owner address 0xe80d171dbe7898ef93d0b2be621d2978921c471a can no longer mint and has no pause, burn or upgrade function. The V10 Hub on Base is owned by a MultiSigWallet at 0x4cd6467b797846e63a27c92350d040c428394068 that needs 2 of 3 signatures. Through the Hub this multisig can swap in new contract addresses, which is the V10 upgrade path, and add staking lock tiers. The signers are not publicly identified.

(Source: Blockscout, TracToken Contract, Blockscout, Base Hub Owner, Contract Addresses, Pre-Mainnet Bug Bounty)

(f) Current economic arrangements and distribution policies

No protocol fee or revenue flows to Trace Labs. The protocol treasury fee would take up to 10% of staker-bound publishing fees once governance sets a recipient, and it stays at 0% today. Trace Labs holds a TRAC treasury for OriginTrail's development and pays bug bounties in TRAC. No formally adopted policy directs treasury assets to its equityholders.

(Source: Conviction and Economics, Staking and Migration, Trace Labs, OriginTrail and TRAC, General Bug Bounty)

Token Supply & Allocations

06Initial Allocation

Disclose launch and initial supply details in a single initial allocation schedule covering the token's launch.

  • (a) Launch supply totals — The total number of tokens issued at launch, the total number of tokens locked at launch or the total number of tokens unlocked at launch.
  • (b) Recipient categories & use of funds — The recipient categories with brief explanations as to how the category will use the tokens so an auditor can distinguish each bucket.
  • (c) Initial price per token (if applicable) — The initial price per token at TGE. If the token launched via a liquidity bootstrapping mechanism, auction, or other price-discovery process rather than a fixed offering price, describe that mechanism and the final market set price instead. If no fixed price was set, state so.
  • (d) Ticker / market symbol — The ticker/market symbol.
  • (e) Total supply & supply regime — The total supply and whether the supply is fixed (if not explain inflation rate or deflation rate).
  • (f) Initial vesting / release schedules — The initial vesting/release schedules (identify which categories/recipients are subject to vesting and the high-level timing logic).

Response

(a) Launch supply totals

All 500,000,000 TRAC were minted at launch in January 2018. The token contract held about 74,990,394 TRAC for team and founders and 32,000,000 TRAC for pre-ICO contributors and advisors under time locks, so about 106,990,394 TRAC were locked at launch. The remaining 393,009,606 TRAC went to sale contributors and to team wallets without a contract lock. Transfers were scheduled to open on January 24, 2018 at 15:00 UTC.

(Source: Blockscout, TracToken Contract, Token Release Update)

(b) Recipient categories & use of funds

  • Category: Token sale contributors
    • Allocation: 50%
    • Tokens: 250,000,000 TRAC
    • Use: Presale and crowdsale buyers, who also received about 9,606 TRAC created by the sale contract error
  • Category: Future development
    • Allocation: 20%
    • Tokens: 100,000,000 TRAC
    • Use: Trace Labs development treasury, minted to a team multisig wallet
  • Category: Team and founders
    • Allocation: 15%
    • Tokens: 75,000,000 TRAC
    • Use: Founders and team, reduced by about 9,606 TRAC to offset the sale contract error
  • Category: Pre-ICO contributors and advisors
    • Allocation: 8%
    • Tokens: 40,000,000 TRAC
    • Use: Early contributors and advisors
  • Category: Liquidity pool
    • Allocation: 5%
    • Tokens: 25,000,000 TRAC
    • Use: Exchange liquidity, minted to a team multisig wallet
  • Category: Bounty
    • Allocation: 2%
    • Tokens: 10,000,000 TRAC
    • Use: Community bounty rewards during the token sale

(Source: Blockscout, TracToken Contract, What is OriginTrail (TRAC))

(c) Initial price per token (if applicable)

The presale price was $0.08 per TRAC for 125,000,000 TRAC, and the crowdsale price was $0.10 per TRAC for 125,000,000 TRAC, with ETH as the only accepted currency. The sale reached its combined hard cap of $22.5 million in January 2018.

(Source: ICO Drops, OriginTrail, OriginTrail ICO Reaches Hard Cap, What is OriginTrail (TRAC))

(d) Ticker / market symbol

TRAC. The token was first issued under the symbol TRACE and reissued as TRAC in January 2018.

(Source: Blockscout, TRAC Token, Token Release Update)

(e) Total supply & supply regime

TRAC has a fixed supply of 500,000,000 tokens. The contract's total supply reads exactly 500,000,000 TRAC onchain, and its minting has been finished permanently, so no new TRAC can be created. TRAC has no burn function. The project states that all tokens are in circulation.

(Source: Blockscout, TRAC Token, TRAC Token, OriginTrail Ecosystem White Paper 2.0)

(f) Initial vesting / release schedules

  • Category: Team and founders
    • Vesting terms: Held in the token contract and released in eight quarterly tranches of 9,375,000 TRAC after 90, 180, 270, 360, 450, 540, 630 and 720 days from January 15, 2018 at 15:00 UTC, with the first tranche reduced by about 9,606 TRAC
    • Circulating status: no
  • Category: Pre-ICO contributors and advisors
    • Vesting terms: 20% released at allocation, then 40% after 90 days and 40% after 180 days from January 15, 2018
    • Circulating status: no
  • Category: Token sale contributors
    • Vesting terms: No lock-up, transferable from January 24, 2018 at 15:00 UTC
    • Circulating status: no
  • Category: Future development, liquidity pool and bounty
    • Vesting terms: Minted to a team multisig wallet with no contract lock
    • Circulating status: no

(Source: Blockscout, TracToken Contract, Token Release Update, TRAC Token)

07Airdrop Process

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.

  • (a) Planned but not yet executed airdrop — If the project has planned but not yet airdropped, commit to publishing a recipient wallet list in a public channel and provide it to Blockworks quarterly until the initial TGE airdrop is fully completed. Additionally, generally state the possible target user segments (e.g., "stakers of X," "Aave users") and the allocation method (e.g., proportional to ve-balance or net position).
  • (b) Executed airdrop — If the project has already airdropped, point to a per-address source such as CSV/TSV/JSON files, a Dune table, a full Merkle dump, GitHub repo files embedding per-address allocations, or RPC endpoints that expose claim/amount data; explorer links alone do not count. Additionally, clearly state covered user segments (e.g., "stakers of X," "Aave users") and the allocation method (e.g., proportional to ve-balance or net position).
  • (c) No airdrop planned or conducted — If the project does not plan to conduct an airdrop for TGE and has never conducted one, state so plainly (e.g., "We have never conducted an airdrop to date and do not plan to execute one").

Response

Planned but not yet executed airdrop

Not applicable. No planned TRAC airdrop is announced in the OriginTrail docs or on the TRAC token page.

(Source: TRAC Token, OriginTrail Docs)

Executed airdrop

The only community distribution at launch was the 10,000,000 TRAC bounty pool, 2% of supply, which the token contract minted to a team multisig wallet. It was a bounty allocation to be paid out by January 26, 2018 at 15:00 UTC. The published campaigns split it by task. A translation bounty reserved 75,000 TRAC for eight languages and paid by stakes per translated item (whitepaper 100 stakes, project overview 50, token sale page 10, product page 10, announcement thread 10), with applicants accepted through a form (Bitcointalk, OriginTrail Translation Bounty, 2017-11-28). A Community Reward Program set aside 15,000 TRAC of the 10,000,000 TRAC bounty allocation for community contributions (Bitcointalk, OriginTrail Community Reward Program, 2017-12-06). The split of the rest of the pool is not published. No per-address source for the bounty exists in the reviewed record, and the token contract, the OriginTrail docs and the Token Release Update contain no CSV, Merkle dump, Dune dashboard or claim endpoint.

(Source: Blockscout, TracToken Contract, Token Release Update)

No airdrop planned or conducted

Not applicable. The 2018 bounty distribution is treated as an executed airdrop.

(Source: Token Release Update)

Transactions & Market Structures

08Market Maker Agreements & Deals

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:

  • (a) Market maker's name — the market maker's name;
  • (b) Token allocation or loaned amount — the token allocation or loaned amount as a percentage of total supply;
  • (c) Duration/term of agreement — the duration/term of the agreement; and, where applicable,
  • (d) Name of agreement structure — label the financial vehicle being used in the agreement (i.e. loan, option/call, retainer model) without describing trading strategy or expected outcomes.

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

  • Market Maker Name: Wintermute, under a strategic partnership Trace Labs announced in November 2021 to support major TRAC exchange pairs and add TRAC to Wintermute's OTC desk (IQ.wiki, Trace Labs).
    • Token Allocation Committed: No TRAC loan or allocation to Wintermute is publicly disclosed (IQ.wiki, Trace Labs).
    • Term Duration: The term of the Wintermute partnership is not publicly disclosed.
    • Structure Name: The agreement structure, whether loan, option or retainer, is not publicly disclosed.

09CEX / DEX Agreements & Deals

Projects must disclose all material terms of centralized or decentralized exchange listings that affect token liquidity. For each listing, include in a table:

  • (a) Exchange name / DEX pool — the exchange name (and, for DEX, the specific pool/pair);
  • (b) Token allocation for listing — the token allocation supplied or committed for listing as a percentage of total supply;
  • (c) Term Duration — the duration/term of any listing lockups, liquidity, or incentive programs; and, where applicable,
  • (d) Native-token listing fees — whether any listing fees were paid in native tokens, with amounts (tokens or % of supply), recipients, and any vesting or lock terms tied to the partnership.

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

  • Exchange Name: Centralized venues Coinbase, Kraken, Binance.US, KuCoin, Bitstamp, Bitget, Bitvavo, HTX, Crypto.com and Gate.io, as listed on the TRAC token page (TRAC Token).
    • Token Allocation Committed: No TRAC allocation for any of these listings is publicly disclosed, and the 25,000,000 TRAC liquidity pool minted at launch is not tied to any named venue (Blockscout, TracToken Contract).
    • Term Duration: No listing lockup, liquidity or incentive term is publicly disclosed for these venues.
    • Native Token Listing Fees: No listing fee paid in TRAC is disclosed, and a community guide states that Trace Labs stands against paying for exchange listings (Trace Labs, OriginTrail and TRAC).
  • Exchange Name: Uniswap, listed on the TRAC token page (TRAC Token); the Uniswap v2 TRAC/WETH pair is 0x1a58aa618df8f1ec282748fef6185c1a1cc2faa6, which held about 45,083 TRAC as of 2026-10-06 (Blockscout, Uniswap V2 TRAC/WETH Pair).
    • Token Allocation Committed: No project-supplied TRAC liquidity for a Uniswap pool is publicly disclosed (TRAC Token).
    • Term Duration: No liquidity lockup or incentive term is publicly disclosed for Uniswap.
    • Native Token Listing Fees: No listing fee applies to a permissionless Uniswap pool, and none paid in TRAC is disclosed.

Financial Disclosures & Risks

10Prior Token Sales & Fundraising

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:

  • (a) Series Name
  • (b) Early-Stage Investment Instrument used (i.e. SAFT, STAMP, SAFE, SAFE+Token Warrant, etc.)
  • (c) Date of sale (at least month & year)
  • (d) Number of tokens sold (or % of total supply)
  • (e) Vesting schedule

If no prior sales occurred, state that explicitly (e.g., "No prior fundraising, OTC, or discounted MM sales have occurred.").

Response

  • Series Name: Presale of the Trace token at $0.08 per token with a $10 million hard cap (ICO Drops, OriginTrail).
    • Investment Vehicle: Direct public token sale paid in ETH through the sale smart contract, with no SAFT or SAFE disclosed (ICO Drops, OriginTrail, Token Release Update).
    • Date Of Sale: The presale took place in January 2018, and the sale reached its hard cap in about 18 minutes (OriginTrail ICO Reaches Hard Cap).
    • Number of tokens sold: The presale sold 125,000,000 TRAC, or 25% of total supply (ICO Drops, OriginTrail).
    • Vesting Schedule: Presale tokens had no lock-up and were scheduled to become transferable on January 24, 2018 at 15:00 UTC (Token Release Update).
  • Series Name: Crowdsale of the Trace token at $0.10 per token with a $12.5 million cap (ICO Drops, OriginTrail).
    • Investment Vehicle: Direct public token sale paid in ETH through the sale smart contract, with no SAFT or SAFE disclosed (ICO Drops, OriginTrail).
    • Date Of Sale: The crowdsale closed in January 2018 at the combined $22.5 million hard cap (OriginTrail ICO Reaches Hard Cap).
    • Number of tokens sold: The crowdsale sold 125,000,000 TRAC, or 25% of total supply (ICO Drops, OriginTrail).
    • Vesting Schedule: Crowdsale tokens had no lock-up and were scheduled to become transferable on January 24, 2018 at 15:00 UTC (ICO Drops, OriginTrail, Token Release Update).
  • Series Name: Pre-ICO contributor allocation, which the token contract groups with advisors (Blockscout, TracToken Contract).
    • Investment Vehicle: The instrument and price for pre-ICO contributors are not publicly disclosed, and a community guide states that Trace Labs avoided pre-sales to venture capitalists (Trace Labs, OriginTrail and TRAC).
    • Date Of Sale: The pre-ICO contributions predate the January 15, 2018 sale start, and their exact month is not publicly disclosed (Blockscout, TracToken Contract).
    • Number of tokens sold: Pre-ICO contributors share a 40,000,000 TRAC bucket, 8% of supply, with advisors, and the split between them is not publicly disclosed (Blockscout, TracToken Contract).
    • Vesting Schedule: The bucket released 20% at allocation, 40% after 90 days and 40% after 180 days from January 15, 2018 (Blockscout, TracToken Contract).

11Previous Exploits Affecting The Native Token

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").

  • (a) Date & component affected — Date (YYYY-MM or YYYY-MM-DD), chain(s)/component affected.
  • (b) Exploit vector summary — Plain-language summary of the exploit vector (what the hack was).
  • (c) Quantified impact — Quantified impact (assets/tokens affected or a clear "no loss of funds" statement).
  • (d) Remediation/response taken — Remediation/response taken (patches, upgrades, governance actions, compensation).
  • (e) Current status — Current status (resolved, in litigation, under investigation, refunded, etc.).
  • (f) References (optional) — References (optional): link(s) to post-mortem/advisory/PR.

Response

(a) Date & component affected

One incident affected the native token, in 2018-01 on Ethereum, in the original TRACE token sale contract. No other exploits affecting tokenholders or protocol funds have been publicly reported as of 2026-10-05. The review covered the current TRAC contract, the OriginTrail docs and bug bounty pages, and public coverage of TRAC since 2018.

(Source: Token Release Update, Blockscout, TracToken Contract, General Bug Bounty)

(b) Exploit vector summary

This was a coding error, not a hack. The sale contract checked new purchases against the 500,000,000 total supply instead of the 250,000,000 tokens for sale, so it minted about 9,605.5 TRACE beyond the sale cap. Because of the excess, the team could not call the function that closed the sale and enabled transfers.

(Source: Token Release Update)

(c) Quantified impact

About 9,605.5 excess TRACE were created, and the OriginTrail team reported no security failure and no loss of funds. Total supply was kept at 500,000,000.

(Source: Token Release Update)

(d) Remediation/response taken

The OriginTrail team deployed a new token contract under the symbol TRAC carrying all contributor balances, with an expedited Hosho audit planned, and left the old TRACE tokens locked. The excess was deducted from the founders' pool, and the live contract encodes this as a correction of about 9,605.6 TRAC taken from the first founder tranche.

(Source: Token Release Update, Blockscout, TracToken Contract)

(e) Current status

Resolved. TRAC was scheduled to become transferable on January 24, 2018 at 15:00 UTC, and the replacement contract still reads a total supply of exactly 500,000,000 TRAC.

(Source: Token Release Update, Blockscout, TRAC Token)

(f) References (optional)

The Token Release Update published in January 2018 is the post-mortem for this incident, and the verified TracToken source shows the correction.

(Source: Token Release Update, Blockscout, TracToken Contract)

12Material Risk Factors (Regulation, Technology, Token Economics)

Describe material risk factors across the three categories below. Each category includes prompts to address at a minimum.

  • (a) Regulatory, Legal & Tax Risks — Describe how evolving laws and regulations could affect the project by answering, at a minimum, questions like:

  • Impact of Regulatory Change on TGE and Listings: (If applicable) How could evolving or conflicting laws and regulations affect your ability to complete the TGE, deliver tokens to purchasers, and list or maintain the token on trading venues in key jurisdictions?

  • Entity-Level Regulatory Impact: (If applicable) How could regulatory or legal changes impact your core entities (Foundation, DevCo, DAO, affiliated service providers), including enforcement actions, licensing requirements, or forced changes to structure or operations?

  • Tokenholder Tax Treatment: (If applicable) What uncertainties exist around how tokenholders may be taxed, and make clear that tokenholders are responsible for understanding their own tax obligations?

  • Jurisdictional & User Access Restrictions: (If applicable) If the project restricts access for certain jurisdictions or user types (e.g., U.S. persons, sanctioned countries, retail vs. professional), what are those restrictions and what risks do they create for users and for the project?

  • (b) Protocol, Technology & Security Risks — Describe risks to network and contract reliability, correctness, and safety by answering, at a minimum, questions like:

  • Bugs and Design Flaws: (If applicable) What bugs, design flaws, or implementation errors could exist in your core protocol code, smart contracts, and any bridges, rollups, or oracles that you depend on, and how could these lead to loss of funds or disruption of the protocol?

  • Security Measures & Their Limitations: (If applicable) What security measures have you taken (audits, formal verification, bug bounties), and what types of failures might these measures still fail to detect or prevent?

  • (c) Token Economics, Unlocks & Incentive Risks — Describe how the token's economic design and supply schedule could affect holders by answering, at a minimum, questions like:

  • Critical Economic Assumptions: (If applicable) Which economic assumptions (e.g., staking yields, fee revenue, liquidity incentives, MEV capture, demand for blockspace) are critical for protocol security, utility, and governance, and what happens if those assumptions fail?

  • Governance Control over Monetary Policy & Rewards: (If applicable) To what extent can governance change monetary policy, fee parameters, or reward allocations (e.g., inflation rate, treasury flows, incentive programs), and how could such changes adversely affect tokenholders?

Response

(a) Regulatory, Legal & Tax Risks

Impact of Regulatory Change on TGE and Listings:

The TRAC sale ended in January 2018 and all tokens have been delivered, so no TGE remains to complete. TRAC trades on venues in several jurisdictions, including Coinbase, Kraken, Binance.US and Bitvavo, and each venue can delist it if local rules change. The V10 terms describe TRAC as a utility token rather than an investment and place MiCA compliance on the user, and no MiCA white paper for TRAC appears in the reviewed record. A regulator that treated TRAC differently could restrict trading or staking in its market.

(Source: TRAC Token, DKG V10 Terms and Conditions)

Entity-Level Regulatory Impact:

The project rests on Trace Labs Ltd. in Hong Kong and OriginTrail, digitalne rešitve za dobavne verige, d.o.o. in Slovenia. The V10 terms are governed by Slovenian law with the courts of Ljubljana as forum. A change in Hong Kong or EU rules on token issuers, staking services or software developers could force licensing, reporting or changes to how these companies support the network. A community guide states that Trace Labs has no legal obligations towards retail holders.

(Source: Trace Labs Terms and Conditions, OriginTrail Terms and Conditions, DKG V10 Terms and Conditions, Trace Labs, OriginTrail and TRAC)

Tokenholder Tax Treatment:

The project gives no tax guidance for buying, holding, staking or selling TRAC. Staking rewards, Staking Conviction NFTs and bridged TRAC on Base, Gnosis and NeuroWeb may each be taxed differently from one jurisdiction to another, for example as income on receipt or only on disposal. The V10 terms state that users are solely responsible for their own taxes. Tokenholders are responsible for understanding their own tax obligations.

(Source: DKG V10 Terms and Conditions, Staking and Migration)

Jurisdictional & User Access Restrictions:

The V10 terms bar persons located, organised or resident in any jurisdiction under comprehensive UN, EU, UK or US sanctions, including OFAC programs, and persons on sanctions lists. No restriction on US persons or retail users is published. Users who breach these terms risk losing access, and the project carries enforcement risk if sanctioned persons use the network.

(Source: DKG V10 Terms and Conditions, Pre-Mainnet Bug Bounty)

(b) Protocol, Technology & Security Risks

Bugs and Design Flaws:

Staking positions on V10 are ERC-721 NFTs tied to staked TRAC, so a flaw that breaks the link between a position and its backing stake could put staked TRAC at risk. The Hub owner multisig can swap in new contracts, so a compromised key or a faulty replacement could change staking logic. TRAC on Base, Gnosis and NeuroWeb depends on Superbridge, OmniBridge and Snowbridge, and a bridge failure could leave bridged TRAC unbacked. The 2018 sale contract error shows that token logic bugs have occurred before.

(Source: Pre-Mainnet Bug Bounty, Bridging TRAC, Token Release Update)

Security Measures & Their Limitations:

Before V10 went live, a 300,000 TRAC pre-mainnet bounty was held with a live honeypot on Base, whose first phase ran from June 10 to 17, 2026, and its plan adds a continuous general audit phase with security reports sent through GitHub Private Vulnerability Reporting. A separate general bounty pays up to 1,000 TRAC for website and app bugs. The 2018 sale contracts were audited by DLT Labs and Hosho. The V10 terms state that the node source code has not necessarily passed a third-party audit, and no formal verification is disclosed. Bounties cannot prevent a multisig key compromise, a bridge failure or a bug that no researcher reports.

(Source: Pre-Mainnet Bug Bounty, GitHub OriginTrail/dkg, General Bug Bounty, Token Release Update, DKG V10 Terms and Conditions)

(c) Token Economics, Unlocks & Incentive Risks

Critical Economic Assumptions:

Staking rewards come only from publishers paying TRAC to publish and update Knowledge Assets. If publishing demand falls, stakers and node operators earn less and may leave, which weakens the network. The V10 launch plan set V8 publisher commitments to emit to stakers over up to 2 years rather than 5, which raises rewards now and lowers them later unless new publishing replaces them. Stakers in locked tiers cannot exit early if conditions worsen. Trace Labs also controls a development treasury that an undated community guide puts at over 100 million TRAC, with no published lock or current balance, which could be sold.

(Source: Conviction and Economics, V10 Mainnet Release Timeline, Staking and Migration, Trace Labs, OriginTrail and TRAC)

Governance Control over Monetary Policy & Rewards:

TRAC supply cannot change because minting is permanently finished. Reward parameters can change. The protocol treasury fee is governance-set up to 10% of staker-bound fees and stays at 0% until wider consensus is reached, and the Hub owner multisig adds lock tiers and can replace staking contracts. Turning on the fee would cut staker rewards by up to a tenth, and a contract change could alter how rewards are split.

(Source: Blockscout, TracToken Contract, Conviction and Economics, Staking and Migration, Pre-Mainnet Bug Bounty)

This Token Transparency Filing is provided for general informational purposes only and does not verify or warrant the accuracy of individual answers.

Contents

  1. Project & Team
  2. 01Description of Project
  3. 02Known Project Team
  4. 03DAO Structure
  5. 04Primary Foundation
  6. 05Primary Dev Co
  7. Token Supply & Allocations
  8. 06Initial Allocation
  9. 07Airdrop Process
  10. Transactions & Market Structures
  11. 08Market Maker Agreements & Deals
  12. 09CEX / DEX Agreements & Deals
  13. Financial Disclosures & Risks
  14. 10Prior Token Sales & Fundraising
  15. 11Previous Exploits Affecting The Native Token
  16. 12Material Risk Factors (Regulation, Technology, Token Economics)
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