Question
Provide a concise narrative that clearly states each of (a)–(e) below.
Response
Traders who want to swap tokens across many blockchains face scattered liquidity and need intermediaries such as traditional market makers. Sushi, also known as SushiSwap, is a decentralized exchange created in late August 2020 that lets users swap tokens through liquidity pools without a traditional market maker. It operates across more than 40 chains and aggregates liquidity sources on those networks through its RouteProcessor 6 router to find the best swap price for users.
(Source: What Is Sushi FAQ, How Does Sushi Work FAQ)
Sushi Labs, the development arm set up after the 2024 Burū no Shinka vote, funds development and operations from protocol revenue and DAO treasury support. The December 2025 emissions proposal states that Sushi Labs generated over $10M in revenue in 2024 and sets a goal of $20M in annual recurring revenue. The December 2024 Treasury Diversifications vote passed diversified treasury funds to Sushi Labs to pay for infrastructure, personnel, product expansion and research. The September 2026 tokenomics restructure directs all protocol fees left after buybacks and reserve purchases to Sushi Ops for development, incentives, partnerships, liquidity, security and operations.
(Source: Introducing Sushi Labs, Snapshot, AER Increase Implementation, Snapshot, Treasury Diversifications Implementation, Snapshot, Tokenomics Restructure Implementation)
SushiSwap is an automated market maker in which liquidity providers deposit token pairs into pools and swappers trade against those pools. Each swap pays a 0.3% fee, of which 0.25% goes to liquidity providers and 0.05% goes to SUSHI holders who stake into xSUSHI. On top of its own pools, Sushi runs an aggregator through RouteProcessor 6, which can route trades across outside liquidity sources, and it serves as the core DEX on the Katana network.
SUSHI is the primary token of the SushiSwap platform and was first distributed as liquidity mining rewards. Holders stake SUSHI in the Sushi Bar to receive xSUSHI, which accumulates value as the platform collects fees. SUSHI held as xSUSHI or in qualifying positions counts toward SushiPowah, the voting power used in Snapshot votes, where a proposal needs at least 5 million SushiPowah to be valid.
(Source: What Is SUSHI FAQ, What Is xSUSHI FAQ, Sushi Governance FAQ)
Sushi relies on offchain Snapshot votes that multisigs then execute. The SUSHI token is owned by the MasterChef contract, MasterChef is owned by a Timelock with a 48-hour delay, and the Timelock admin is a 3-of-5 OPS Safe, while a 4-of-6 Treasury Safe receives the MasterChef developer share. Since the 2024 move to a Labs model, Sushi Labs runs daily operations. The governance FAQ states that a working, trustless DAO remains a goal without a timeline.
(Source: Blockscout, MasterChef, Blockscout, Timelock, Safe API, OPS Safe, Safe API, Treasury Safe, Sushi Labs FAQ, Sushi Governance FAQ)
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 |
|---|---|---|---|
Jared Grey | Labs/DevCo | Jared Grey is the former Head Chef of Sushi and was named Managing Director of Sushi Labs in June 2024 (Introducing Sushi Labs). | Grey is an engineer and multi-time founder with over 20 years in technology who served as CEO of EONS and Bitfineon, and Sushi voters appointed him Head Chef on October 3, 2022 with nearly 11M of 13M votes (Introducing Head Chef Jared Grey). |
Omakase (pseudonymous) | Labs/DevCo | Omakase was described by Sushi as its core frontend developer (The Power of BentoBox). | The reviewed sources publish no legal name or prior roles for Omakase beyond frontend work on Sushi and BentoBox (The Power of BentoBox). |
Jiro (pseudonymous) | Labs/DevCo | Jiro was named Lead Sushi Developer in a November 2023 partnership announcement (Sushi Partners with ZetaChain). | The reviewed sources publish no legal name or prior roles for Jiro beyond leading Sushi integrations such as ZetaChain (Sushi Partners with ZetaChain). |
No officers of the Sushi DAO Foundation are publicly named, and the 2022 legal structure vote, the 2023 legal entity update and the 2024 review describe the entity without listing directors or council members (Snapshot, Sushi Legal Structure Implementation, Snapshot, Legal Entity Update Signal, Sushi 2024 Review). | Foundation | The 2022 structure gave the Cayman DAO Foundation a governance council, and no titles for its members have been published (Snapshot, Sushi Legal Structure Implementation). | No Foundation officers are named, so there is no prior experience to report. |
Adarsh Bhatt | DAO/Onchain Governance | Adarsh Bhatt was appointed to the Sushi High Kitchen by a vote that closed in August 2024 with 5,394,996 votes in favor (Snapshot, High Kitchen Adarsh Bhatt). | Bhatt describes himself as an early-stage investor in the web3 ecosystem who has worked closely with a Sushi Labs member (Snapshot, High Kitchen Adarsh Bhatt). |
Hypotenuse Labs | DAO/Onchain Governance | Hypotenuse Labs was appointed to the Sushi High Kitchen by a vote that closed in August 2024 with 5,394,857 votes in favor (Snapshot, High Kitchen Hypotenuse Labs). | Hypotenuse Labs is a developer team active in crypto and AI since 2018 that cites governance experience at Nouns DAO (Snapshot, High Kitchen Hypotenuse Labs). |
Adam Ambrozy | DAO/Onchain Governance | Adam Ambrozy was appointed to the Sushi High Kitchen by a vote that closed in August 2024 with 5,394,840 votes in favor (Snapshot, High Kitchen Adam Ambrozy). | The application under his vote describes the founder of a DAO administration infrastructure startup, although its body text carries another candidate's name in the name field (Snapshot, High Kitchen Adam Ambrozy). |
Kevin Michael Kozeny | DAO/Onchain Governance | Kevin Michael Kozeny was appointed to the Sushi High Kitchen by a vote that closed in August 2024 with 5,394,869 votes in favor (Snapshot, High Kitchen Kevin Michael Kozeny). | Kozeny is an angel investor in crypto and technology, a United States Navy veteran and a past participant in ApeCoin DAO (Snapshot, High Kitchen Kevin Michael Kozeny). |
Sarang | DAO/Onchain Governance | Sarang was appointed to the Sushi High Kitchen by a vote that closed in October 2024 with 8,005,263 votes in favor and 1,103 against (Snapshot, High Kitchen Sarang). | Sarang has been a SushiSwap core developer since 2021, is an advisor to SushiSwap, previously sat on the team multisig and has served on the Abracadabra and Aura multisigs (Snapshot, High Kitchen Sarang). |
Question
Provide a structured description of the DAO's governance, powers, and economic rights. If a DAO does not exist, state so. Address the lettered items below. Even if there is no DAO, there must be an answer to (d).
Response
The Sushi DAO itself owns no disclosed IP. The Terms of Service state that the services and their software, text, images and design belong to Sushi Holdings Ltd. as the Company, its licensors or other providers. Sushi Studios projects receive a royalty-free, perpetual license to the Sushi brand, and the reviewed sources do not name the entity that grants that license. The core code is open source: the sushi-labs/sushiswap repository, published under the Sushi Labs GitHub organization, carries an MIT license, and MasterChef.sol is marked SPDX MIT. No Sushi trademark registration was found in the reviewed sources.
(Source: Sushi Terms of Service, Sushi Studios, GitHub API, sushi-labs/sushiswap, fetched October 6, 2026, MasterChef.sol)
Proposals pass on the sushigov.eth Snapshot space and need at least 5 million SushiPowah to be valid, after which multisig signers execute them. MasterChef owns the SUSHI token and is in turn owned by a Timelock with a 48-hour delay whose admin is the 3-of-5 OPS Safe, so that Safe can queue MasterChef pool, allocation and migrator changes. The Treasury Safe is a 4-of-6 multisig, and High Kitchen members appointed by Snapshot vote serve as multisig signers. The governance FAQ still describes older thresholds of six of nine treasury signers and three of six operations signers, and the onchain Safe configurations above govern. No pause role over the SUSHI token is disclosed.
(Source: Sushi Governance FAQ, MasterChef.sol, Blockscout, Timelock, Safe API, OPS Safe, Safe API, Treasury Safe, Snapshot, High Kitchen Kevin Michael Kozeny)
Staking SUSHI in the Sushi Bar returns xSUSHI, which accumulates value from platform fees and counts toward SushiPowah voting power. Other qualifying positions are WETH-SUSHI liquidity tokens, MEOWSHI, tSushi and axSushi. SushiPowah holders can approve major structural changes, while day-to-day operations, pool rebalancing, business strategy and development are left to the team.
(Source: What Is xSUSHI FAQ, Sushi Governance FAQ)
xSUSHI holders receive the 0.05% share of each 0.3% swap fee under the fee model the FAQ describes, and the 2024 review reports more than $2M of SUSHI rewards to xSUSHI holders. The September 2026 restructure, passed with 5,214,574 votes for and none against, replaces this with 1% of protocol fees plus 1% of perpetuals fees for monthly xSUSHI buybacks and 4% of protocol fees for weekly purchases into a protocol-controlled SUSHI Reserve. Holders do not receive treasury distributions, and the DAO votes on treasury use through Snapshot.
(Source: How Does Sushi Work FAQ, Sushi 2024 Review, Snapshot, Tokenomics Restructure Implementation)
No single party holds a disclosed authority to dissolve the Sushi DAO. The governance FAQ states that major structural changes are always voted on by the community, so a dissolution would follow the general route of a sushigov.eth Snapshot vote meeting the 5 million SushiPowah minimum, executed by the multisigs. No dissolution-specific threshold is published. The 2022 legal structure vote placed the DAO's real-world administration in a Cayman Islands foundation, and that vote and the Sushi Labs FAQ set out no separate wind-down mechanism. A June 2024 Sushi post states that the Sushi DAO is not being replaced or dissolved.
(Source: Snapshot, Sushi Legal Structure Implementation, Sushi Governance FAQ, Sushi Labs FAQ, Sushi DAO Remains in Operation)
Question
For the Primary Foundation do the following independently. If an entity does not exist, state that explicitly. Items (a)–(f) apply only if that entity exists; state explicitly that the entity doesn't exist.
Definitions: The primary Foundation and DevCo can be explained as those entities which are directly involved in the issuance of the native token at launch.
Response
The primary foundation is the Sushi DAO Foundation, a Cayman Islands foundation approved by a Snapshot vote that closed on October 26, 2022 with 10,658,524 votes for and 178 against. The same vote created a Panamanian Foundation to administer the protocol smart contracts and a Panamanian Corporation, wholly owned by that foundation, to run the front end. A 2023 signal vote moved the legal work to Gresham International to widen the structure, and the 2024 review reports that the Sushi DAO Foundation was finalized. The registered legal name and registration number are not published. SUSHI launched in August 2020, before any of these entities existed.
(Source: Snapshot, Sushi Legal Structure Implementation, Snapshot, Legal Entity Update Signal, Sushi 2024 Review, What Is Sushi FAQ)
The 2022 vote gave the Panamanian Foundation the administration of the AMM, Kashi and staking contracts and gave its subsidiary Panamanian Corporation the front end. The current Terms of Service instead name Sushi Holdings Ltd. as owner of the services and their contents, so the Foundation's own IP holdings today are not disclosed.
(Source: Snapshot, Sushi Legal Structure Implementation, Sushi Terms of Service)
Under the 2022 vote, the DAO Foundation's governance council can administer the treasury and grants, run the onchain governance process and facilitate proposals and voting. The January 2026 MasterChef migration vote states that a majority of fees from protocol-deployed liquidity is intended to be captured by the Sushi Foundation and compounded back into that liquidity. The reviewed sources do not name a Foundation address among the Safe or Timelock roles.
(Source: Snapshot, Sushi Legal Structure Implementation, Snapshot, MasterChef LP Migration Implementation)
The Foundation has no disclosed ownership of Sushi Labs or Sushi Holdings Ltd. The 2022 vote provided that the foundations would sign service agreements with providers chosen by later proposals, and the Sushi Labs FAQ states that the DAO oversees governance and regulates the treasury. Those agreements and any Foundation influence over Sushi Labs decisions are not published.
(Source: Snapshot, Sushi Legal Structure Implementation, Sushi Labs FAQ)
The Foundation holds no disclosed pause, upgrade or executor role over SUSHI. The token is owned by MasterChef, MasterChef is owned by a 48-hour Timelock administered by the 3-of-5 OPS Safe, and the Treasury Safe is a 4-of-6 multisig, and none of these is publicly attributed to the Foundation.
(Source: Blockscout, MasterChef, Blockscout, Timelock, Safe API, OPS Safe, Safe API, Treasury Safe)
The January 2026 MasterChef migration vote, passed with 5,216,119 votes for, intends that a majority of fees from redeployed protocol liquidity go to the Sushi Foundation, with a portion reserved for the Sushi Bar and SUSHI rewards for historical liquidity providers. No token allocation, salary or other distribution to Foundation officers is disclosed.
Question
For the Primary DevCo do the following independently. If an entity does not exist, state that explicitly. Items (a)–(f) apply only if that entity exists; state explicitly that the entity doesn't exist.
Definitions: The primary Foundation and DevCo can be explained as those entities which are directly involved in the issuance of the native token at launch.
Response
The development company is Sushi Labs; the sushi.com Terms of Service name Sushi Holdings Ltd. as the Company. The Terms of Service, last modified August 12, 2026, name Sushi Holdings Ltd. as the Company and are governed by the laws of the United Kingdom. The privacy policy names Sushi Holdings Limited, P.O. Box 4301, Trinity Chambers, Tortola, British Virgin Islands, as data controller, with gunnercooke GmbH in Berlin as EU representative, and the site's cookie notice states that personal data is processed by Sushi Labs and its partners. Sushi Labs was set up after the 2024 Burū no Shinka vote, which passed on April 17, 2024 with 18,837,134 votes for and 230,413 against. SUSHI launched in August 2020 under the pseudonymous founder Chef Nomi, before Sushi Labs existed.
(Source: Sushi Terms of Service, Sushi Privacy Policy, Introducing Sushi Labs, Snapshot, Burū no Shinka Implementation, CoinDesk, Chef Nomi Returns Dev Fund)
Sushi Holdings Ltd. owns the services and their entire contents, including software, text, images and design, under the Terms of Service. Sushi launched Sushi Studios in February 2023, before Sushi Labs existed, and it gives incubated projects a royalty-free, perpetual license to the Sushi brand. The ownership link between Sushi Labs and Sushi Holdings Ltd. and any other subsidiaries are not disclosed.
(Source: Sushi Terms of Service, Sushi Studios)
Sushi Labs receives diversified treasury funds and manages their composition at its sole discretion under the December 2024 Treasury Diversifications vote, which passed with 11,616,355 votes for and 979 against. Under the December 2025 emissions vote, the core team adjusts SUSHI emission allocations across AMM liquidity, listings, private capital deals and growth programs within a ceiling of 5% of supply per year. The Sushi team posts proposals to Snapshot, and Sushi Labs committed to quarterly disclosures to the DAO.
(Source: Snapshot, Treasury Diversifications Implementation, Snapshot, AER Increase Implementation, How to Create a Proposal FAQ, Introducing Sushi Labs)
Sushi Labs has no disclosed ownership of or control over the Sushi DAO Foundation. A June 2024 Sushi post states that the DAO is not being replaced or dissolved, and the Sushi Labs FAQ states that the DAO will continue to oversee governance, regulate the treasury and take part in council elections through SushiPowah.
(Source: Sushi Labs FAQ, Sushi DAO Remains in Operation)
Sushi Labs holds no publicly attributed pause, upgrade or executor role over SUSHI. Token administration runs through MasterChef, its 48-hour Timelock and the 3-of-5 OPS Safe, and treasury execution runs through the 4-of-6 Treasury Safe, and the reviewed sources do not identify which signers are Sushi Labs staff.
(Source: Blockscout, Timelock, Safe API, OPS Safe, Safe API, Treasury Safe)
The September 2026 tokenomics restructure directs all protocol fees, migration fees and other protocol revenue left after xSUSHI buybacks and SUSHI Reserve purchases to Sushi Ops, which funds development, incentives, partnerships, liquidity, security and operations. The December 2024 Treasury Diversifications vote sends diversified treasury assets to Sushi Labs for infrastructure, personnel, product expansion and research. MasterChef also mints one tenth of each block reward to the developer address, which is the Treasury Safe.
(Source: Snapshot, Tokenomics Restructure Implementation, Snapshot, Treasury Diversifications Implementation, MasterChef.sol, Blockscout, MasterChef)
Question
Disclose launch and initial supply details in a single initial allocation schedule covering the token's launch.
Response
SUSHI launched in late August 2020. No tokens existed at launch, and supply has been minted over time by MasterChef as liquidity mining rewards, plus a one-tenth share to the developer address. The onchain total supply now reads 291,514,753.90 SUSHI across 130,743 holders.
(Source: What Is Sushi FAQ, MasterChef.sol, Blockscout API, SUSHI Token)
(Source: MasterChef.sol, What Is MasterChef FAQ, Blockscout, MasterChef)
No fixed price was set.
(Source: What Is Sushi FAQ, What Is SUSHI FAQ)
SUSHI.
(Source: Blockscout API, SUSHI Token)
SUSHI supply is not fixed. The Sushi docs state that SUSHI has no hard-capped maximum supply, that block rewards continue indefinitely at a base of 100 SUSHI per block, and that governance can adjust reward rates. A November 2023 Sushi post stated that SUSHI had finished minting a total supply of 250M with no new emissions. Onchain, minting resumed through MasterChef pool 125, whose staked tokens are held by the OPS Safe. On May 9, 2024 an OPS Safe deposit minted 12,134,800 SUSHI to MasterChef plus 1,213,480 to the Treasury Safe, and on May 27, 2024 a second deposit minted 12,523,700 plus 1,252,370, taking supply from about 250.21M to 277.33M. Smaller harvest mints from November 2024 to February 2026 took supply to about 287.68M, and an April 2, 2026 deposit minted 3,489,444.17 plus 348,944.42, taking supply to the current 291,514,753.90. No Snapshot vote authorizing the May 2024 reactivation was found. MasterChef now gives pool 125 32,852 of 1,000,000 allocation points, which works out to about 3.29 SUSHI per block plus a one-tenth developer share, and these rewards are minted only when the pool is next harvested. The December 2025 emissions vote, passed with 5,214,144 votes for and 1,071 against, raised the annual emissions rate from 1.5% to up to 5% of total supply, or about 14.25M SUSHI a year at 285M supply. A November 2023 signal vote on new tokenomics failed with 9,826,116 votes against.
(Source: Sushi Docs, Tokenomics, fetched October 6, 2026, Kanpai Expires, xSUSHI Revived, Etherscan, May 9, 2024 mint, Etherscan, May 27, 2024 mint, Etherscan, April 2, 2026 mint, Blockscout, MasterChef, Blockscout API, SUSHI Token, Snapshot, AER Increase Implementation, Snapshot, Deploy New Tokenomics Signal)
(Source: Merkle Tree Clawback, Snapshot, Merkle Clawback Implementation, Snapshot, Merkle Distributor Transfer, MasterChef.sol)
Question
Address each of the following sub-items based on the project's airdrop status. If a sub-item does not apply to the project's situation, state that explicitly.
Response
Planned but not yet executed airdrop
Not applicable. Sushi has announced no planned SUSHI airdrop.
(Source: Sushi Governance FAQ)
Executed airdrop
Not applicable. SUSHI has never been distributed by airdrop, and the Merkle distributor held vested liquidity mining rewards rather than an airdrop.
(Source: Merkle Tree Clawback)
No airdrop planned or conducted
Sushi has never conducted a SUSHI airdrop to date and has announced none. SUSHI entered circulation through MasterChef, as liquidity mining rewards (directly or through the vested Merkle distributor) and a one-tenth developer share. The review covered the Sushi FAQs and blog, the MasterChef contract and the sushigov.eth Snapshot proposals, and none of them describes an airdrop. The January 2026 MasterChef migration vote reserves a portion of future fees for SUSHI rewards to historical liquidity providers, and no recipient list or schedule for those rewards is published.
(Source: What Is SUSHI FAQ, , , )
Question
Projects must disclose all material terms of market-making arrangements that affect token liquidity. If the project has no agreements or deals with market makers, state that explicitly; doing so earns full credit. For each market maker, include in a table:
If the project has no agreements or deals with market makers, state that explicitly; doing so earns full credit. If no native tokens were loaned or allocated to market makers, state that explicitly; cash/fiat retainers or fees are not required for this item.
Response
Question
Projects must disclose all material terms of centralized or decentralized exchange listings that affect token liquidity. For each listing, include in a table:
If the project has no agreements or deals with CEX or DEX, state that explicitly; doing so earns full credit; cash/fiat fee amounts are not required for this item.
Response
Question
Disclose all prior token sales by the Project — including fundraising rounds, any material OTC sales to investors, and any discounted market-maker sales. For each sale, provide:
If no prior sales occurred, state that explicitly (e.g., "No prior fundraising, OTC, or discounted MM sales have occurred.").
Response
Question
If any, list prior exploits or incidents that directly affected the token, token supply, tokenholder balances, token contract, minting controls, burn mechanics, or custody of token supply. This question is not asking about general protocol, application, or smart contract exploits unless the incident directly affected the native token itself.
If no prior incidents, state this explicitly (e.g., "No exploits affecting tokenholders or protocol funds as of YYYY-MM-DD").
Response
2020-09, Ethereum. The pseudonymous creator Chef Nomi sold the SUSHI held in the developer fund, the share of supply that MasterChef mints to the developer address.
(Source: CoinDesk, Chef Nomi Returns Dev Fund, MasterChef.sol)
This was an insider sale rather than a code exploit. The developer address was controlled by a single person, who liquidated the fund's SUSHI holdings for ETH without warning.
(Source: CoinDesk, Chef Nomi Returns Dev Fund, Bitcoin.com News, Chef Nomi Returns $14M)
The sale produced about 38,000 ETH, worth about $14 million at the time, and was followed by a 73% fall in the SUSHI price.
(Source: CoinDesk, Chef Nomi Returns Dev Fund)
Chef Nomi transferred control of the project to FTX CEO Sam Bankman-Fried and, on September 11, 2020, returned the 38,000 ETH to the original developer fund wallet. Control of MasterChef has since moved to a Timelock with a 48-hour delay administered by the 3-of-5 OPS Safe, and the developer address is now the 4-of-6 Treasury Safe.
(Source: CoinDesk, Chef Nomi Returns Dev Fund, Blockscout, Timelock, Safe API, OPS Safe, Safe API, Treasury Safe)
Resolved, with the funds returned in September 2020. No other incident affecting the SUSHI token, its supply, holder balances or minting controls has been publicly reported as of 2026-10-05. The 2023 RouteProcessor2 exploit hit user token approvals rather than SUSHI and is covered in Section 12.
Question
Describe material risk factors across the three categories below. Each category includes prompts to address at a minimum.
(a) Regulatory, Legal & Tax Risks — Describe how evolving laws and regulations could affect the project by answering, at a minimum, questions like:
Impact of Regulatory Change on TGE and Listings: (If applicable) How could evolving or conflicting laws and regulations affect your ability to complete the TGE, deliver tokens to purchasers, and list or maintain the token on trading venues in key jurisdictions?
Entity-Level Regulatory Impact: (If applicable) How could regulatory or legal changes impact your core entities (Foundation, DevCo, DAO, affiliated service providers), including enforcement actions, licensing requirements, or forced changes to structure or operations?
Tokenholder Tax Treatment: (If applicable) What uncertainties exist around how tokenholders may be taxed, and make clear that tokenholders are responsible for understanding their own tax obligations?
Jurisdictional & User Access Restrictions: (If applicable) If the project restricts access for certain jurisdictions or user types (e.g., U.S. persons, sanctioned countries, retail vs. professional), what are those restrictions and what risks do they create for users and for the project?
(b) Protocol, Technology & Security Risks — Describe risks to network and contract reliability, correctness, and safety by answering, at a minimum, questions like:
Bugs and Design Flaws: (If applicable) What bugs, design flaws, or implementation errors could exist in your core protocol code, smart contracts, and any bridges, rollups, or oracles that you depend on, and how could these lead to loss of funds or disruption of the protocol?
Security Measures & Their Limitations: (If applicable) What security measures have you taken (audits, formal verification, bug bounties), and what types of failures might these measures still fail to detect or prevent?
(c) Token Economics, Unlocks & Incentive Risks — Describe how the token's economic design and supply schedule could affect holders by answering, at a minimum, questions like:
Critical Economic Assumptions: (If applicable) Which economic assumptions (e.g., staking yields, fee revenue, liquidity incentives, MEV capture, demand for blockspace) are critical for protocol security, utility, and governance, and what happens if those assumptions fail?
Question
Identify to the best of your ability the token's current deployments across chains, including project-issued deployments, project-endorsed representations, and, if possible, documented third-party wrapped or bridged representations.
For each entry, provide:
Multiple entries on the same chain are permitted.
Definition: A protocol-level asset is an asset whose balances and transfers are handled directly by the blockchain's core rules, rather than by a token smart contract. For protocol-level assets without a token contract address, enter "No contract address" and identify the asset and chain.
Response
This Token Transparency Filing is provided for general informational purposes only and does not verify or warrant the accuracy of individual answers.
CoinDesk and Bitcoin.com News covered the sale and the return of funds. Sushi has published no post-mortem for this event.
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
Impact of Regulatory Change on TGE and Listings:
Its listings, such as Kraken and Binance.US, depend on each venue's view of the token's legal status, and a change in US, UK or EU rules on governance tokens could lead a venue to delist SUSHI or restrict it for some users. In March 2023 the SEC served subpoenas on the Sushi DAO and Head Chef Jared Grey, which shows that US regulators have examined the project.
(Source: CoinDesk, SEC Subpoena, Kraken Listing, Binance.US Listing)
Entity-Level Regulatory Impact:
Sushi spreads its activities across Sushi Holdings Ltd. in the British Virgin Islands, a Cayman Islands DAO Foundation and Panamanian entities approved in 2022, with Terms of Service governed by UK law. A change in rules in any of these places could force licensing, reporting or structural changes, and the 2023 SEC subpoenas led Grey to propose a legal defense fund for contributors. The Sushi DAO itself has no published legal wrapper beyond the Foundation, which leaves the liability of voters and signers unsettled.
(Source: Sushi Privacy Policy, Sushi Terms of Service, Snapshot, Sushi Legal Structure Implementation, CoinDesk, SEC Subpoena)
Tokenholder Tax Treatment:
Sushi gives no tax guidance for SUSHI, and the Terms of Service state that no tax advice is given through the services. Liquidity mining rewards, xSUSHI value growth and the September 2026 xSUSHI buybacks may be taxed as income in some jurisdictions and only on disposal in others, and the treatment of LP positions moved in the 2026 MasterChef migration is unsettled. Tokenholders are responsible for understanding their own tax obligations.
(Source: Sushi Terms of Service, Snapshot, Tokenomics Restructure Implementation, Snapshot, MasterChef LP Migration Implementation)
Jurisdictional & User Access Restrictions:
The Terms of Service bar residents of Algeria, Bolivia, Belarus, Crimea, Cuba, Donetsk, the Democratic Republic of Congo, Iran, Iraq, Ivory Coast, Liberia, Libya, Luhansk, Mali, Myanmar, Nepal, North Korea, Somalia, Sudan, Syria, Tunisia, Venezuela, Yemen and Zimbabwe. They also bar any country under US, UK or EU embargo and any place that restricts crypto trading. Disputes go to UK courts subject to arbitration, which makes claims costly for users elsewhere, and these limits narrow access to the front end, although the contracts remain usable onchain.
(Source: Sushi Terms of Service)
Bugs and Design Flaws:
On April 8, 2023 Sushi deployed RouteProcessor2 to 14 networks with an approval flaw, and because the contract could not be paused or upgraded, MEV bots copied a whitehat rescue and drained about 1,800 WETH from one user. HYDN rescued over $750k, 885 ETH was returned and Sushi committed to make users whole, opening a claim portal on April 26, 2023. RouteProcessor 6 can stay closed source behind a verified RedSnwapper contract, which limits outside review. The Timelock owner can also add a migrator to MasterChef that moves staked LP tokens.
(Source: RouteProcessor2 Post-Mortem, RP6 Announcement, MasterChef.sol, Snapshot, MasterChef LP Migration Implementation)
Security Measures & Their Limitations:
Sushi has run an Immunefi bug bounty since March 26, 2021 with a maximum bounty of $200,000, paying critical smart contract findings between $20,000 and $200,000, capped at 10% of economic damage, in USDC or SUSHI. Certora reviewed MasterChef V2, BentoBox, Kashi and Trident in 2021, and Pashov Audit Group lists two Sushi reports. These measures cannot stop a compromised multisig key, a harmful proposal that voters approve or approval exploits in non-upgradeable routers, so Sushi directs users to revoke stale approvals through revoke.cash.
(Source: Immunefi, SushiSwap, Certora Security Reports, Pashov Audits, Revoke Approvals FAQ)
Critical Economic Assumptions:
SUSHI value rests on Sushi's fee revenue, because xSUSHI buybacks and SUSHI Reserve purchases are funded from protocol fees. The December 2025 emissions vote raised the annual emissions ceiling to 5% of supply on the assumption that new incentives will grow revenue toward $20M a year. If volume and fees fail to grow, emissions of up to about 14.25M SUSHI a year would dilute holders while buybacks stay small, since only 1% of protocol fees plus 1% of perpetuals fees now go to xSUSHI buybacks.
(Source: Snapshot, AER Increase Implementation, Snapshot, Tokenomics Restructure Implementation)
Governance Control over Monetary Policy & Rewards:
SushiPowah holders can change emissions, fee routing and treasury use through Snapshot, and the core team adjusts emission allocations within the approved ceiling. Recent votes drew about 5.2M SushiPowah, just over the 5M validity minimum, so a small group of large holders can pass monetary changes. The 2026 restructure cut the xSUSHI share of fees and sent the remainder to Sushi Ops, and similar votes could further reduce holder value.
(Source: Snapshot, AER Increase Implementation, Snapshot, Tokenomics Restructure Implementation, Sushi Governance FAQ)
