RWA Sonar

Issuer programme dossier

Ondo Global Markets

The holder owns an unsecured-in-form but collateral-secured debt claim on Ondo Global Markets (BVI) Limited — a blockchain-based tracker certificate / structured note whose redemption amount tracks the total return of the referenced share or ETF.

livestructured-note280 exact Solana tokensclaim rung 2 · secured claim on collateral
Observed20 Sep 2026 07:53 UTC Coverage49 of 50 required fields sourced Basis140 structured claims · current reviewed understanding LimitUnknown means not established, never “no”

The short answer

What do you own?secured claim on collateral

The holder owns an unsecured-in-form but collateral-secured debt claim on Ondo Global Markets (BVI) Limited — a blockchain-based tracker certificate / structured note whose redemption amount tracks the total return of the referenced share or ETF.

Understand ownership →
Can you redeem?Yes

Only 'Onboarded Purchasers' who have completed the issuer's full KYC and satisfy the eligibility criteria (non-US person, not a Prohibited Person, and in several jurisdictions professional/accredited-investor status).

Understand redemption →
Can the issuer intervene?Issuer intervention is possible through clawback, freeze, pause, allowlist, transfer hook.

Control is reported as observed powers, not collapsed into a score.

Understand issuer powers →
Backing verificationdaily-verification-agent

Verified 2026-09-17: the reports are individual PDFs in a public Dropbox folder named ‘PUBLIC - Ondo Stocks Daily Reports’, 248 files from 2025-10-01 to 2026-09-15, filenames ‘Daily Report - Ondo Stocks - YYYY-MM-DD_20_00_ET - Ankura Attestation.pdf’ (earlier files use ‘OGM’).

Understand insolvency protection →

Published claim ≠ observed reality

These are changes or conflicts in the outside world—not a history of edits to RWA Sonar’s own research.

warning

README implies Pyth validates GM-token prices; the code uses an issuer-written stock price

Published claim

The official programme README advertises “Price validation via Pyth oracle feeds with sanity checks” as a programme-wide oracle integration.

Observed reality

For GM stocks, the signed quote is checked against OracleSanityCheck.last_price, which Ondo role key 5NC6Q8… writes directly. The published source uses Pyth PriceUpdateV2 only in the separate USDC peg check—not as an independent equity-price oracle.

Why it matters: A holder should not read “Pyth” as independent validation of the referenced share price. Both the executable quote and its stock-price sanity anchor remain inside Ondo’s operational trust boundary.

Technology + legal templates

These conclusions apply only to the exact programme and observed control recipe shown.

Current Solana assets

280 exact token addresses currently inherit this issuer-level analysis unless an asset card records an exception.

Legal claim and issuing chain
Issuing entity
Ondo Global Markets (BVI) Limited — BVI business company, bankruptcy-remote SPV, 90.01% owned by Flux Finance Inc. (Ondo Foundation subsidiary) and 9.99% by Ondo Finance Inc.; Ondo Finance Inc. (Greenwich, CT) acts as Tokenizer/service provider
Entity jurisdiction
British Virgin Islands
Governing law
Swiss law governs the form/transfer/cancellation of the tokens as Ledger-Based Securities under arts. 973d et seqq. CO, and governs the Sales Terms (arbitration: Swiss Rules, seat Zurich, English). Collateral Agreement and Alpaca account control agreement: New York law. BitGo account control agreement: South Dakota law. Administrative Services Agreement: Delaware law. Base Prospectus approved under EU Prospectus Regulation by the Liechtenstein FMA.
Regulatory status
Not a registered US offering. Tokens sold only outside the US under Regulation S; issuer not registered as an investment company under the 1940 Act. EU-facing: Base Prospectus for a 'Program for the issuance of tokenized Securities' approved by the Liechtenstein Financial Markets Authority on 11.11.2025 (valid to 11.11.2026), with per-asset Final Terms filed with the FMA and PRIIPs Key Information Documents; NVDAon carries ISIN VGG7001AAH73. Some assets carry an 'Admission to Trading Notice on Binance MTF in Abu Dhabi Global Market'. Ondo Finance Inc. filed a no-action request with SEC Trading & Markets on 2026-04-13 to tokenize the DTC security entitlements that collateralise OGM products (via its SEC-registered transfer agent Oasis Pro TA, LLC) — that request does not cover issuance of the OGM tokens themselves. Two pending or historical items. (1) A confidential SEC registration statement for Ondo Stocks was announced by Ondo on 2026-02-03 (blog datePublished 2026-02-03T15:15:00Z) which, once effective, on Ondo's own account "would make Ondo Stocks the first issuer of transferable tokenized stocks to be subject to the SEC's reporting requirements". Nothing published shows it has gone effective, so this is a pending and not currently effective. (2) The SEC is reported to have closed a multi-year investigation into Ondo Finance without charges — UNVERIFIED: no readable primary source was available, so the report remains undated; it concerned Ondo Finance Inc. and the ONDO token, not Ondo Global Markets (BVI) Limited or these tokens.
Holder claim
The holder owns an unsecured-in-form but collateral-secured debt claim on Ondo Global Markets (BVI) Limited — a blockchain-based tracker certificate / structured note whose redemption amount tracks the total return of the referenced share or ETF. The holder has a put option to redeem for cash/stablecoin at the tracked value, plus the benefit of a first-priority perfected security interest in the collateral held by Ankura Trust Company as Security Agent; the holder has no shareholder voting or information rights. Physical delivery of the underlying is excluded under the Sales Terms and no party may demand conversion into certificated, uncertificated or book-entry securities — with one documented exception outside the Sales Terms: authorized participants with a linked Alpaca brokerage account can redeem Ondo Stocks for the underlying securities through Alpaca's Instant Tokenization Network (ITN) on Ethereum and BNB Chain.
Underlying custodian
Alpaca Securities LLC (SEC-registered, FINRA member broker-dealer; New York) holds the equities/ETFs through the DTC indirect holding system and provides the trading/clearing accounts. BitGo Trust Company, Inc. (Sioux Falls, SD) holds fiat and stablecoins/tokens. The 2026-09-10 Ankura report also names SVB, Coinbase, Circle, Anchorage and a 'Bridge Account' and 'PSM' as holding locations for cash/stablecoins.
Redemption and holder eligibility
Available
Yes
Eligibility
Only 'Onboarded Purchasers' who have completed the issuer's full KYC and satisfy the eligibility criteria (non-US person, not a Prohibited Person, and in several jurisdictions professional/accredited-investor status). KYC is an express condition precedent to redemption, so a secondary-market buyer may hold a token it cannot redeem. Onboarding was institutional-only at the time of the Solana launch, with retail 'coming soon'.
Route / rails
On-chain atomic mint/redeem against USDon (the platform stablecoin), with USDC atomically swapped 1:1 to/from USDon via a stablecoin swapper (users are not whitelisted for that swap by default). Requires an off-chain signed attestation (secp256k1) from the Ondo GM API quoting price and amount, submitted to the on-chain program by a whitelisted address. For an ordinary Onboarded Purchaser redemption is for cash/stablecoin only, and the Sales Terms exclude physical delivery and bar any conversion into certificated, uncertificated or book-entry securities. Separately, Alpaca's Instant Tokenization Network lets authorized participants mint from, and redeem into, the underlying securities in a linked Alpaca brokerage account on Ethereum and BNB Chain (no Ondo fee for ITN mint/redeem). Bank wire redemption not supported.
KYC
Yes
Minimum
$1.00 USD to invest or redeem
Fees
Sales Terms define Purchaser Fees owed to the Issuer for issuance AND redemption of up to 0.1% of the market price of the Underlyings; no separate redemption fee is advertised in the docs, and Ondo also retains the spread between the quoted token price and the price at which it trades the underlying. Ondo charges no fee for mint/redeem through Alpaca's ITN channel. Investor pays gas. Dividends are reinvested net of 30% US withholding tax on the BVI issuer.
Timing
Not established
Transfer mechanism
freeze-authority
US persons excluded
Yes
Backing, custody and insolvency
Collateral ratio
1:1+buffer
Composition
may-include-other
Rehypothecation
prohibited
Bankruptcy remote
Yes
Security interest
Yes
Verification type
daily-verification-agent
Verification agent
Ankura Trust Company, LLC (New Hampshire LLC, 140 Sherman Street, 4th Floor, Fairfield, CT 06824) — acts as both Verification Agent and Security Agent
Verification frequency
Daily, per Business Day, measured as of 8:00pm ET — but on a multi-day contractual clock: the Issuer owes Ankura the data by 11:59pm GMT on the THIRD Business Day after the Calculation Day (the "Report Day"), and Ankura's report is then due by 4:30pm GMT on the next calendar day after the Issuer Report Day. Monthly reconciliation: Issuer data within 15 days of month end, Ankura report within 5 Business Days thereafter. First Calculation Day 2025-10-01.
Verification notes
Verified 2026-09-17: the reports are individual PDFs in a public Dropbox folder named ‘PUBLIC - Ondo Stocks Daily Reports’, 248 files from 2025-10-01 to 2026-09-15, filenames ‘Daily Report - Ondo Stocks - YYYY-MM-DD_20_00_ET - Ankura Attestation.pdf’ (earlier files use ‘OGM’). The link is hardcoded in the app.ondo.finance asset-page JS bundle (chunk 3718-bc04a4affdc06794.js) behind CMS feature flag ‘showGmPdpAttestationLinks’ (enabled in prod); monthly reports are a second Dropbox folder (https://www.dropbox.com/scl/fo/7rlmba8f49nvbp3xwz1of/ABv0vSjd6cIDAUTIlwm2KwA?rlkey=hokf0tffqvezfmsto25cvpovs&dl=0). No API, no CSV/JSON, no Chainlink PoR, no on-chain reserve feed. Content is issuer-level, not per-mint: the 2026-09-15 report shows Total Assets $1,257,853,141.27 vs Total Liabilities $1,156,926,839.49 and an Asset-to-Obligation Ratio of 108.72%, covering Ondo Stocks, USDon and USDY together (the 2026-09-10 report: $1,229,196,568.57 / $1,137,983,260.72 / 108.02%). Ankura states it reviewed the figures ‘based solely on account data and reports submitted by Issuer or otherwise independently accessed ... through read-only access’ — a review, not an audit, and s.8.3 disclaims responsibility for the accuracy of what it is given. DISCREPANCY: Sales Terms s.8.1(b) requires posting to https://ondo.finance/global-markets; that page carries no report links at all (re-checked 2026-09-17: no occurrence of ‘Ankura’, ‘Dropbox’ or any attestation link). The publication lag is NOT a lapse: s.8.1(a) gives the Issuer until the third Business Day after each Calculation Day to deliver the data, so the 2026-09-15 report appearing on 2026-09-17 is within the contractual schedule.

How custody affects DeFi enforcement →

Corporate actions and economics
Dividends
reinvested
Voting
preference-passthrough
Corporate actions
Voting: since 2026-04-28, via a Broadridge integration, tokenholders can express non-binding voting PREFERENCES to the issuer regarding the shares the issuer beneficially owns; the issuer has no legal obligation to follow them, and the holder has no shareholder voting right. Dividends are reinvested into the referenced stock net of withholding tax and expressed as an increase in the 'shares per token' multiplier; on Solana this is surfaced through the Token-2022 ScaledUiAmount extension, so the displayed balance grows rather than the price (NVDAon multiplier 1.0017152487959897, AAPLon 1.003376073740221, SPYon 1.0077209101501272, TSLAon 1.0 as read on-chain 2026-09-16). Stock splits are handled the same way. Trading is paused around ex-dividend dates (roughly 7:50-8:10pm ET the day before the ex-date) and halted for ETF distributions until the amount is known; assets enter a reduced-size 'limited' state around earnings. Halts are listed at status.ondo.finance. The issuer may replace the Underlying held as collateral, and may exercise an Issuer Call Option to terminate and redeem all (not part) of a token series after a Termination Notice.
Pricing
reference market: exchange-nbbo · arbitrageable: true · notes: Primary-market mint/redeem quotes are derived from the NYSE/NASDAQ price of the underlying plus the reinvested-dividend multiplier, delivered as a user- and mint-bound secp256k1 attestation with a short validity window and a spread retained by Ondo. The on-chain programme checks that quote against an issuer-written last_price, not a Pyth equity feed; Pyth is used only to check the USDC leg. The GM API exposes both 'primaryMarket' (token) and 'underlyingMarket' (off-chain stock) prices. Arbitrage between primary and secondary markets is available only to onboarded/whitelisted participants, so secondary DEX prices can drift: secondary liquidity is thin (Jupiter reported ~$491 of liquidity against ~$3.55m FDV for NVDAon on 2026-09-16). Trading follows US market sessions with an off-hours session; the issuer disclaims any representation about secondary-market price.
Primary documents and evidence

Inspect source freshness and individual claims →

Open research questions (11)