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STEPN

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Compiled by Blockworks·B1 v1.1·Filed 05 Oct 2026Partial - 8 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)
  17. Token Addresses and Deployments
  18. 13[Optional] Token Addresses and Deployments
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

Question

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

STEPN is a Web3 lifestyle app that uses game and social elements to reward users for moving outdoors. Users equip NFT Sneakers and walk, jog or run to earn GST and GMT, which turns everyday exercise into a rewarded activity. The project placed 4th out of more than 500 entries at the Solana Ignition Hackathon in 2021.

(Source: STEPN Whitepaper Overview, Binance Research)

(b) Operational priorities

STEPN funds ongoing development and operations from an Ecosystem and Treasury allocation that unlocks 0.3% of total GMT supply, or 18,000,000 GMT, each month, with unspent GMT held in the STEPN treasury. The team commits no less than 5% of its profit to the stability and growth of the Find Satoshi Lab ecosystem. DOOAR swap fees also route 0.1% of each trade to future development.

(Source: Governance & Ecosystem Fund, )

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)
  17. Token Addresses and Deployments
  18. 13[Optional] Token Addresses and Deployments
Decentralized Exchange

(c) High-level project overview

Users hold NFT Sneakers in the STEPN app and earn GST, the in-game token with unlimited supply, and GMT, the governance token, when they move outdoors. GPS and movement data verify each session before tokens are issued. The app includes a marketplace, a wallet and the DOOAR swap, and Find Satoshi Lab Limited, a British Virgin Islands company, operates the service.

(Source: STEPN Whitepaper Overview, Tokenomic, Decentralized Exchange, Privacy Policy)

(d) Primary token functions

GMT is the governance token of STEPN with a hard cap of 6,000,000,000 tokens. Users earn it with Rainbow Sneakers or level-30 Classic Sneakers, spend it in the STEPN Marketplace and MOOAR, and burn it for in-app upgrades. Holders stake GMT for voting power, and a longer lock gives more voting power.

(Source: Tokenomic, GMT Vesting & Utility, Binance Research)

(e) Control surface reliance

Find Satoshi Lab Limited holds the main control surface. The Terms of Use let the company amend the Terms, withdraw or amend Services without notice, change the token accumulation rate, reverse benefits granted by mistake or misuse, and suspend or cancel access. The company also runs a machine-learning anti-cheating system on location and movement data. Governance is evolving through the GMT DAO, an independent organization of GMT holders, which ran its first lock-to-vote burn vote from November 2024 to January 20, 2025.

(Source: STEPN Terms of Use, Privacy Policy, Decrypt, GMT DAO Burn, Bitget News, Burn Thresholds)

02Known Project Team

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

Jerry Huang

Labs/DevCo

Co-Founder (Binance Research)

Game developer and former founder of Falafel Games who co-founded STEPN in August 2021 (Metaschool).

Yawn Rong

Labs/DevCo

Co-Founder (Binance Research)

Australian blockchain entrepreneur who founded Crypto SA, served as an Algorand ambassador and represented industry at the South Australian Blockchain Association (Metaschool).

Shiti Manghani

Labs/DevCo

Chief Executive Officer of Find Satoshi Lab since January 2024, previously Chief Operating Officer (Bitget News)

Electronics engineer with an MBA in Marketing and 14 years of managing multi-million-pound projects across 11 countries, who founded an AI computer-vision startup for posture correction before joining Find Satoshi Lab (Startups Magazine, Blockchain Gamer).

Jessica Duan

Labs/DevCo

Chief Strategy Officer (Binance Research)

Executive with a design background and expertise in operations and strategy (Binance Research).

No STEPN foundation exists. The Terms of Use state that STEPN was launched by FindSatoshi Lab Limited, and neither the Terms nor the Data Protection Notice names a foundation (STEPN Terms of Use, Data Protection Notice).

Foundation

No foundation officer titles exist because no foundation has been formed.

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

The GMT DAO is an independent organization of GMT holders, and the reviewed sources name no individual DAO leaders (Decrypt, GMT DAO Burn).

DAO/Onchain Governance

The GMT DAO has no named officeholders or council titles in the reviewed sources (Decrypt, GMT DAO Burn).

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

03DAO Structure

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).

  • (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

The GMT DAO owns or controls no disclosed IP. The Terms of Use state that all intellectual property in the app and Services remains with Find Satoshi Lab Limited or its licensors, and no license to the DAO appears in the Terms, the whitepaper or the DAO launch coverage.

(Source: STEPN Terms of Use, Decrypt, GMT DAO Burn)

(b) Contract/admin powers

The GMT DAO decides by lock-to-vote. Holders locked GMT on burngmt.com to vote on burning up to 600 million GMT, with results recorded onchain, and Find Satoshi Lab confirmed on January 20, 2025 that 60 million GMT would be burned. Token administration sits with Find Satoshi Lab rather than the DAO. After June 17, 2023 the Ethereum mint rights were burned and ERC-GMT moved to a multi-signature address for monthly distribution, and the whitepaper does not disclose that address's signers or threshold. Find Satoshi Lab minted 70,000,000 POL-GMT on July 5, 2024 and minted GMT on Polygon as recently as February 13, 2025, when it minted 709,504,827 pGMT. The Verilog audit found that the owner of the BNB Chain GreenSatoshiToken contract can mint unlimited GST.

(Source: Decrypt, GMT DAO Burn, FSL on X, Burn Result, Governance & Ecosystem Fund, Verilog Audit, HackMD)

(c) Locked-token rights (conditional)

Holders lock GMT to gain voting power, and a longer lock gives more voting power. Stakers vote on how staking rewards are distributed. In the 2024 to 2025 burn vote, locked GMT decided how much of the up-to-600-million-GMT burn went ahead and earned a share of 100 million GMT in milestone-based rewards, distributed after the 60-day voting period. Holders cannot decide app parameters, token accumulation rates, which the Terms reserve to Find Satoshi Lab.

(Source: Binance Research, Decrypt, GMT DAO Burn, STEPN Terms of Use)

(d) Value accrual & holder rights

GMT holders have no right to revenue distribution or treasury assets. DOOAR charges a 1% swap fee, and the 0.6% sent to an ecosystem address may be used for GMT buyback and burn, sneaker buyback and burn, events and giveaways. Holders do not direct this flow, and their only treasury-related right so far was the 2024 to 2025 vote on burning up to 600 million GMT, which ended with 60 million GMT confirmed for burning.

(Source: Decentralized Exchange, Decrypt, GMT DAO Burn, FSL on X, Burn Result)

(e) Dissolution authority

No party holds a disclosed authority to dissolve the GMT DAO, and the DAO has no disclosed legal wrapper or dissolution vote threshold. The Terms of Use, the whitepaper governance page and the DAO launch coverage were reviewed and none sets out a wind-down mechanism.

(Source: STEPN Terms of Use, Governance & Ecosystem Fund, Decrypt, GMT DAO Burn)

04Primary Foundation

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.

  • (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 for STEPN or GMT. The Terms of Use state that STEPN was launched by FindSatoshi Lab Limited, and the Data Protection Notice describes it as a BVI Business Company incorporated in the British Virgin Islands. (Source: STEPN Terms of Use, Data Protection Notice)

(b) IP ownership & control

No primary foundation exists, so no foundation owns or controls STEPN IP and no foundation subsidiaries exist. The Terms of Use state that STEPN was launched by FindSatoshi Lab Limited. (Source: STEPN Terms of Use, Data Protection Notice)

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

No primary foundation exists, so no foundation holds power over the GMT DAO, the treasury, protocol-controlled resources or token administration. (Source: STEPN Terms of Use, Data Protection Notice)

(d) Powers over DevCo

No primary foundation exists, so no foundation can exert direct or indirect influence over Find Satoshi Lab Limited. (Source: STEPN Terms of Use, Data Protection Notice)

(e) Contract/admin powers

No primary foundation exists, so no foundation holds pause, upgrade or governance-executor authority over any GMT contract. (Source: STEPN Terms of Use, Data Protection Notice)

(f) Current economic arrangements and distribution policies

No primary foundation exists, so no mechanism directs protocol-controlled resources, treasury assets, fees, revenue, rewards or token distributions to a foundation, its equityholders or its contributors. (Source: STEPN Terms of Use, Data Protection Notice)

05Primary Dev Co

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.

  • (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

Find Satoshi Lab Limited is a BVI Business Company incorporated in the British Virgin Islands, with its registered address c/o CCS Trustees Limited, Mandar House, 3rd Floor, Johnson's Ghut, Tortola. The Terms of Use set British Virgin Islands law as governing law. The Privacy Policy lists headquarters in the British Virgin Islands and also cites the Australian Privacy Act 1988 (Cth) and the Australian AML/CTF Act 2006 (Cth).

(Source: Data Protection Notice, STEPN Terms of Use, Privacy Policy)

(b) IP ownership & control

Find Satoshi Lab Limited or its licensors own all intellectual property in the app and Services. Find Satoshi Lab is the parent of the STEPN, Gas Hero, MOOAR and DOOAR products. The Terms, Data Protection Notice and Privacy Policy disclose no subsidiary legal entities.

(Source: STEPN Terms of Use, Bitget News, Manghani CEO, Data Protection Notice, Privacy Policy)

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

Find Satoshi Lab can change the token accumulation rate, reverse benefits and suspend access at its own discretion under the Terms. It controls the Ecosystem and Treasury allocation, releasing 18,000,000 GMT each month and holding unspent GMT in treasury addresses on Solana, Ethereum and Polygon. It moved the remaining 3.085 billion GMT of Investor, Advisor, Team and Ecosystem balances to a multi-signature address on Ethereum in June 2023 and runs cross-chain mint and burn operations for exchange liquidity. It set the GMT earnings halving that began on January 1, 2026. The whitepaper does not disclose the multisig threshold for any of these actions.

(Source: STEPN Terms of Use, Governance & Ecosystem Fund, GMT Earning Advanced, STEPN on X, Halving)

(d) Powers over Foundation

No foundation exists, so Find Satoshi Lab has no powers over one. The Terms state that STEPN was launched by FindSatoshi Lab Limited, and neither the Terms nor the Data Protection Notice names a foundation.

(Source: STEPN Terms of Use, Data Protection Notice)

(e) Contract/admin powers

The Verilog audit of the BNB Chain contracts dated April 4, 2022 found that the owner of GreenSatoshiToken.sol can mint unlimited GST and that the owner of STEPNNFT.sol can mint NFTs and change the base URI, and it recommended a multisig. The team replied that unlimited GST supply is intentional. Find Satoshi Lab burned the Ethereum GMT mint rights in June 2023 and later minted GMT on Polygon in July 2024 and February 2025. The Terms let the company amend the Terms and withdraw or amend Services without notice. The whitepaper and audit disclose no pause or upgrade role threshold.

(Source: Verilog Audit, HackMD, Governance & Ecosystem Fund, STEPN Terms of Use)

(f) Current economic arrangements and distribution policies

The Team allocation of 14.2% of supply, or 852,000,000 GMT, is subject to a vesting schedule. No less than 5% of team profit goes back to the ecosystem, and 18,000,000 GMT unlocks monthly from the Ecosystem and Treasury fund. DOOAR's 1% swap fee sends 0.3% to liquidity providers, 0.6% to an ecosystem address that may be used for buybacks, burns, events and giveaways and 0.1% to future development, and the DOOAR trade-fee address converts fees into stablecoins for ecosystem use.

(Source: Binance Research, ICO Drops, Governance & Ecosystem Fund, Decentralized Exchange)

Token Supply & Allocations

06Initial Allocation

Question

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

The full 6,000,000,000 GMT was minted on March 9, 2022. Circulating supply at the Binance listing was 600,000,000 GMT, or 10% of total supply, and the remaining 5,400,000,000 GMT was locked under vesting schedules.

(Source: GMT Vesting & Utility, Binance Research)

(b) Recipient categories & use of funds

  • Category: Move and Earn
    • Allocation: 30.0%
    • Tokens: 1,800,000,000 GMT
    • Use: Rewards for users who move with eligible sneakers and take part in governance
  • Category: Ecosystem and Treasury
    • Allocation: 30.0%
    • Tokens: 1,800,000,000 GMT
    • Use: Released at 18,000,000 GMT per month to build STEPN's global ecosystem, with unspent GMT held in the treasury
  • Category: Private Sale
    • Allocation: 16.3%
    • Tokens: 978,000,000 GMT
    • Use: Sold to private investors at about $0.005 per GMT, raising about $5,000,000
  • Category: Team
    • Allocation: 14.2%
    • Tokens: 852,000,000 GMT
    • Use: Allocated to the team under a vesting schedule
  • Category: Binance Launchpad
    • Allocation: 7.0%
    • Tokens: 420,000,000 GMT
    • Use: Sold to the public at $0.01 per GMT through Binance Launchpad
  • Category: Advisors
    • Allocation: 2.5%
    • Tokens: 150,000,000 GMT
    • Use: Vests to project advisors

(Source: Binance Research, ICO Drops, GMT Vesting & Utility, Governance & Ecosystem Fund)

(c) Initial price per token (if applicable)

The Binance Launchpad sale set a fixed price of 0.01 USD per GMT, or 0.00002514 BNB, on March 9, 2022. The earlier private sale priced GMT at about $0.005.

(Source: Binance Launchpad Completion, Binance Research)

(d) Ticker / market symbol

GMT (Green Metaverse Token).

(Source: Tokenomic, Binance Research)

(e) Total supply & supply regime

GMT has a fixed hard cap of 6,000,000,000 tokens, all minted at TGE. No inflation exists, and the regime is deflationary because GMT is burned for in-app upgrades and through DAO-approved burns such as the 60 million GMT confirmed on January 20, 2025, and DOOAR's 0.6% ecosystem fee share may be used for GMT buyback and burn. The GMT earnings halving that began on January 1, 2026 slows how fast the Move and Earn pool is released. Tokenomist reports 3,111,400,155 GMT unlocked, or 51.86% of supply, as of September 28, 2026.

(Source: Tokenomic, GMT Vesting & Utility, GMT Earning Advanced, FSL on X, Burn Result, Decentralized Exchange, Tokenomist)

(f) Initial vesting / release schedules

  • Category: Binance Launchpad
    • Vesting terms: 100% unlocked at TGE on March 9, 2022, with no lockup
    • Circulating treatment: Circulating treatment: no.
  • Category: Private Sale
    • Vesting terms: 12-month cliff, then 36-month linear vesting, fully unlocked on March 9, 2026
    • Circulating treatment: Circulating treatment: no.
  • Category: Advisors
    • Vesting terms: Cliff, then linear release over 24 months, fully unlocked on March 9, 2025
    • Circulating treatment: Circulating treatment: no.
  • Category: Team
    • Vesting terms: Cliff, then linear release over 48 months, still vesting
    • Circulating treatment: Circulating treatment: yes.
  • Category: Ecosystem and Treasury
    • Vesting terms: 10% at TGE, then linear release of 18,000,000 GMT per month over 90 months
    • Circulating treatment: Circulating treatment: yes.
  • Category: Move and Earn
    • Vesting terms: Released only as users earn GMT through movement and governance participation, with earning enabled on September 28, 2022 and halved from January 1, 2026
    • Circulating treatment: Circulating treatment: conditional.

(Source: Dropstab Vesting, ICO Drops, Governance & Ecosystem Fund, GMT Earning Advanced)

07Airdrop Process

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.

  • (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. STEPN announced its GMT airdrop under the New Horizon Initiative in February 2023, with a snapshot on February 12, 2023, so it is treated as a past airdrop rather than a pending plan.

(Source: Decrypt, New Horizon Airdrop)

Executed airdrop

STEPN announced that the New Horizon airdrop would cover holders of Genesis Sneakers in the Solana realm (G1 to G10,000) and the Ethereum realm (G16,000 to G17,000) at the snapshot on February 12, 2023 at 00:00 UTC. Each sneaker had to sit in the holder's spending account and not be listed for sale. Binance Square reported that GMT would be distributed in the next few days after the snapshot, and no fetched source confirms completion of the distribution. Allocation was a fixed amount per sneaker by rarity, with 4,000 GMT for Common, 8,000 GMT for Uncommon, 16,000 GMT for Rare and 32,000 GMT for Epic sneakers. STEPN has not published a per-address source such as a CSV, Merkle dump, Dune dashboard or claim endpoint for the airdrop. The Decrypt, Binance Square and Coinlive coverage and the whitepaper transparency log were reviewed, and none links a recipient list.

(Source: Decrypt, New Horizon Airdrop, , , )

Transactions & Market Structures

08Market Maker Agreements & Deals

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:

  • (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

No market-maker agreement or deal is publicly disclosed for GMT, and no native tokens are disclosed as loaned or allocated to a market maker. The whitepaper transparency log, the Binance Research project page and the Binance Launchpad announcements were reviewed, and they record treasury, liquidity and burn operations but name no market maker. The exchange liquidity operations are covered in Section 9.

  • Market Maker Name: No market maker is named in the whitepaper transparency log or the Binance Research page (Governance & Ecosystem Fund, Binance Research).
    • Token Allocation Committed: No native GMT is disclosed as loaned or allocated to a market maker.
    • Term Duration: No market-maker term is disclosed because no agreement is disclosed.
    • Structure Name: No loan, option or retainer structure is disclosed.

(Source: Governance & Ecosystem Fund, Binance Research, Binance Launchpad Announcement)

09CEX / DEX Agreements & Deals

Question

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

The Binance Launchpad sale is the only disclosed listing arrangement. The other rows record liquidity operations that Find Satoshi Lab logged in the whitepaper, and none of them has a disclosed lockup or incentive term.

  • Exchange Name: Binance Launchpad, with GMT/BTC, GMT/USDT, GMT/BNB and GMT/BUSD trading from March 9, 2022
    • Token Allocation Committed: 420,000,000 GMT, or 7.0% of supply, sold at $0.01 (Binance Launchpad Announcement, Binance Launchpad Completion)
    • Term Duration: Launchpad tokens had no lockup (ICO Drops).
    • Native Token Listing Fees: The Binance announcements disclose no listing fee paid in GMT.
  • Exchange Name: Binance liquidity operations
    • Token Allocation Committed: 50,000,000 GMT minted as ERC20-GMT for a Binance deposit on December 7, 2022 (0.83%), 70,000,000 POL-GMT on July 5, 2024 (1.17%), and BSC-GMT lock-and-mints of 10,000,000 on April 28, 2024, 2,000,000 on August 12, 2024, 10,000,000 on August 26, 2024 and 2,000,000 on December 9, 2025 (0.17%, 0.03%, 0.17% and 0.03%) ()

Financial Disclosures & Risks

10Prior Token Sales & Fundraising

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:

  • (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: Seed / Private Sale, led by Sequoia Capital India and Folius Ventures with Solana Ventures, Alameda Research, 6th Man Ventures, Sfermion and others (The Block)
    • Investment Vehicle: SAFT (The Block)
    • Date Of Sale: January 2022, announced January 20, 2022 (The Block)
    • Number of tokens sold: 978,000,000 GMT, or 16.3% of supply, at about $0.005 for $5,000,000 (Binance Research, ICO Drops)
    • Vesting Schedule: 12-month cliff, then 36-month linear vesting, fully unlocked on March 9, 2026 (ICO Drops, Dropstab Vesting)
  • Series Name: Binance Launchpad public sale (Binance Launchpad Announcement)
    • Investment Vehicle: Public token sale on Binance Launchpad with BNB subscription and a $15,000 per-user cap (Binance Launchpad Announcement)
    • Date Of Sale: March 9, 2022 (Binance Launchpad Completion)
    • Number of tokens sold: 420,000,000 GMT, or 7.0% of supply, at $0.01 for $4,200,000 (Binance Launchpad Announcement)
    • Vesting Schedule: Fully unlocked at TGE with no lockup (ICO Drops, Dropstab Vesting)

(Source: The Block, Binance Research, ICO Drops, Dropstab Vesting, Binance Launchpad Announcement, Binance Launchpad Completion)

11Previous Exploits Affecting The Native Token

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").

  • (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

No exploits affecting tokenholders or protocol funds have been publicly reported as of 2026-09-28. The review covered the Verilog audit, the whitepaper security and transparency pages, and news coverage of STEPN service incidents. The DDoS attacks of April, May and June 2022 disrupted the app servers and were not attacks on the GMT token contracts, so they fall outside this item.

(Source: Verilog Audit, HackMD, Security, Decrypt, DDoS Attacks)

(b) Exploit vector summary

Not applicable. No exploit vector affecting GMT is on the public record. The June 4, 2022 incident was a denial-of-service attack of 25 million requests on STEPN servers, not an attack on the token contracts.

(Source: Decrypt, DDoS Attacks)

(c) Quantified impact

Not applicable. No reported incident affected GMT, its supply or holder balances, and the June 2022 DDoS attacks targeted STEPN servers rather than the token.

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

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?

Token Addresses and Deployments

13[Optional] Token Addresses and Deployments

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:

  • Token Contract Address or Chain-Specific Asset Identifier
  • Chain
  • Deployment Type: Protocol-level asset / Direct token issuance / Wrapped or bridged representation
  • Project Relationship: Native-token / Project-endorsed / Endorsed third-party / Third-party, endorsement not established / Explicitly unsupported
  • Supporting Source: Link to supporting source

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

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

Binance Square
Coinlive
Governance & Ecosystem Fund

No airdrop planned or conducted

Not applicable. STEPN announced an airdrop to Genesis Sneaker holders in February 2023.

(Source: Decrypt, New Horizon Airdrop)

Governance & Ecosystem Fund
  • Term Duration: The transparency log discloses no term for these operations.
  • Native Token Listing Fees: The transparency log discloses no listing fee paid in GMT.
  • Exchange Name: OKX
    • Token Allocation Committed: 15,000,000 pGMT supplied on September 27, 2024 (0.25%) in exchange for 15,000,000 sGMT returned to the treasury (Governance & Ecosystem Fund)
    • Term Duration: The transparency log discloses no term for this operation.
    • Native Token Listing Fees: The transparency log discloses no listing fee paid in GMT.
  • Exchange Name: Upbit
    • Token Allocation Committed: 709,504,827 pGMT minted on Polygon and sent to Upbit on February 13, 2025 (11.83%), with equivalent sGMT sent to exchanges, eGMT and pGMT burned, and the remaining 460,000,000 GMT to be burnt over the following 7 days (Governance & Ecosystem Fund)
    • Term Duration: The transparency log discloses no term for this operation.
    • Native Token Listing Fees: The transparency log discloses no listing fee paid in GMT.
  • Exchange Name: STEPN GO liquidity pool
    • Token Allocation Committed: 20,000,000 GMT (0.33%) plus 2,000,000 GGT added on November 10, 2024 (Governance & Ecosystem Fund)
    • Term Duration: The transparency log discloses no lock or incentive term for this pool.
    • Native Token Listing Fees: No listing fee applies to this in-ecosystem pool.
  • (Source: Binance Launchpad Announcement, Binance Launchpad Completion, Governance & Ecosystem Fund, ICO Drops)

    (Source: Decrypt, DDoS Attacks)

    (d) Remediation/response taken

    Not applicable. No token exploit required remediation. The Verilog audit of April 4, 2022 found no critical or major issues and two medium centralization findings, and the team replied to them.

    (Source: Verilog Audit, HackMD)

    (e) Current status

    Not applicable. No token incident is open, under investigation or in litigation as of 2026-09-28.

    (Source: Verilog Audit, HackMD, Decrypt, DDoS Attacks)

    (f) References (optional)

    No post-mortem exists because no token exploit occurred. The Verilog audit and the Decrypt DDoS report are the reviewed references.

    (Source: Verilog Audit, HackMD, Decrypt, DDoS Attacks)

  • 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:

    GMT's TGE is complete and it trades on Binance and other venues, so regulatory risk now falls on keeping those listings. Find Satoshi Lab supplies GMT liquidity to Binance, OKX and Upbit through cross-chain operations logged in the whitepaper, including an exchange-requested sGMT liquidity top-up on February 13, 2025. A regulatory restriction or delisting at any of these venues would cut market access and could strand liquidity on one chain.

    (Source: Governance & Ecosystem Fund, Binance Launchpad Completion)

    Entity-Level Regulatory Impact:

    Find Satoshi Lab Limited is a BVI Business Company subject to KYC, AML/CFT, CRS, FATCA, AEOI and BVI Financial Services Commission requirements, and it keeps AML records for at least five years after a customer relationship ends. Its Privacy Policy also cites Australian privacy and AML/CTF law. New licensing rules or enforcement in the British Virgin Islands, Australia or user markets could force changes to onboarding, data handling or token operations. No foundation or DAO legal wrapper shares that burden.

    (Source: Data Protection Notice, Privacy Policy)

    Tokenholder Tax Treatment:

    STEPN gives no tax guidance for earning, spending, burning or trading GMT, and the Terms mention only a sales tax on purchases. Whether move-to-earn rewards count as income when earned or only when sold differs by jurisdiction. Tokenholders are responsible for understanding their own tax obligations.

    (Source: STEPN Terms of Use)

    Jurisdictional & User Access Restrictions:

    The Terms bar users in the United States, China (Mainland), Cuba, Crimea and Sevastopol, Iran, Afghanistan, Syria, North Korea, Antigua and Barbuda, Hong Kong, Thailand, Malaysia, India and Ontario, Canada. The Terms are governed by British Virgin Islands law with exclusive jurisdiction of BVI courts, which makes disputes costly for users elsewhere. Find Satoshi Lab can suspend or cancel access without notice and is not liable for tokens lost through suspension, so users who break these rules risk losing in-app balances.

    (Source: STEPN Terms of Use)

    (b) Protocol, Technology & Security Risks

    Bugs and Design Flaws:

    The Verilog audit found that the owner of GreenSatoshiToken.sol can mint unlimited GST and that the owner of STEPNNFT.sol can mint NFTs and change the base URI. A compromised owner key could therefore inflate GST or change NFT metadata. GMT exists on Solana, BNB Chain, Ethereum and Polygon, and supply is kept consistent by burn-and-mint operations between chains that Find Satoshi Lab and Binance run. A mistake in one of these operations, such as the 709,504,827 pGMT mint of February 13, 2025, could leave supply out of balance across chains. Ethereum mint rights were burned in 2023, but Find Satoshi Lab minted GMT on Polygon as recently as February 13, 2025.

    (Source: Verilog Audit, HackMD, Governance & Ecosystem Fund)

    Security Measures & Their Limitations:

    STEPN relies on the April 2022 Verilog audit, Google 2FA and one-time email codes for users, and a machine-learning anti-cheating system that checks GPS and movement data. The April 2022 HackMD audit covered one commit of the BNB Chain contracts and does not cover later chain deployments, Polygon minting or the Ethereum multisig, whose signers and threshold are undisclosed. The whitepaper Security page also links a February 2025 Verilog audit report (STEPN_Audit_2025_FEB.pdf), whose findings are not reviewed here. None of these measures stops server outages like the three DDoS incidents of 2022. No public bug bounty or formal verification is disclosed on the whitepaper security page.

    (Source: Verilog Audit, HackMD, Security, Privacy Policy, Decrypt, DDoS Attacks)

    (c) Token Economics, Unlocks & Incentive Risks

    Critical Economic Assumptions:

    GMT's value depends on ongoing demand from users who buy sneakers and burn GMT for upgrades, because that demand has to absorb the Move and Earn and Ecosystem emissions. The Ecosystem fund still releases 18,000,000 GMT each month and the Team allocation is still vesting, while Tokenomist shows 51.86% of supply unlocked as of September 28, 2026 with releases scheduled until 2040. If active users decline, burns fall while unlocks continue, which puts pressure on price. The January 1, 2026 halving cuts emissions but also cuts rewards for users.

    (Source: Governance & Ecosystem Fund, Tokenomist, GMT Earning Advanced, Dropstab Vesting)

    Governance Control over Monetary Policy & Rewards:

    Find Satoshi Lab, not tokenholders, controls monetary policy and rewards. The Terms let it change token accumulation rates and reverse benefits, and it set and postponed the halving from October 9, 2024 to January 1, 2026 on its own authority. The first GMT DAO vote was a burn vote, which confirmed 60 million GMT for burning out of a target of up to 600 million GMT, and Find Satoshi Lab has invited a second DAO vote. Holders therefore cannot stop reward cuts, treasury transfers or cross-chain mints that may work against them.

    (Source: STEPN Terms of Use, GMT Earning Advanced, Decrypt, GMT DAO Burn, FSL on X, Burn Result)