Structural Design

The USDtb infrastructure is designed to be fully independent and bankruptcy remote from other business interests. USDtb is issued by Pallas (BVI) Ltd. (“Pallas”), a BVI business company with limited liability. The sole director and shareholder of Pallas is the Pallas Foundation, a Cayman Islands exempted foundation company limited by guarantee. The sole director of the Pallas Foundation is an independent professional director, Marc Piano of Horizons Global. Pallas Foundation has no members, no beneficiaries, and no shareholders - its objects are to support USDtb, including its issuance, redemption, infrastructure, and growth. Ethena Labs (or an affiliate) may be retained by Pallas and/or Pallas Foundation as a service provider.

Pallas is the sole investor and holder of shares in Pallas Fund (BVI) Ltd. (“Pallas Fund”), a BVI business company incorporated with limited liability and recognized by the Financial Services Commission of the British Virgin Islands (the BVIFSC) as a private investment fund. Pallas Fund invests the assets backing USDtb and holds the tokenized U.S. treasury fund products solely in institutional custodial accounts. The initial investment manager for Pallas Fund is Athene Management Limited (“Athene”), an affiliate of Ethena Labs. Athene is recognized by the BVIFSC as an approved manager and retained solely via an investment management services agreement without holding management shares in Pallas Fund. Pallas Fund is controlled by two independent directors, one from each of Horizons Global and Harneys Fiduciary Services. There is no overlap of directors between Pallas Foundation, Pallas Fund, and Athene.

As alluded to previously, a portion of USDtb's backing may be held in stablecoins directly by Pallas in order to facilitate prompt redemptions. These stablecoins are held within institutional custodial solutions.

Users in permitted jurisdictions may inquire with Pallas representatives to determine whether USDtb may fit their needs by sending an email to [e-mail]. Any user wishing to mint and/or redeem USDtb with Pallas is subject to full Know-Your-Customer and Anti-Money Laundering checks. Eligible users cleared via that process may, at Pallas’ discretion and subject to the USDtb Terms and USDtb Mint User Agreement, be whitelisted to mint and redeem USDtb with Pallas (each a “Mint User”). To check whether you are in a permitted jurisdiction and for full eligibility criteria please refer to the USDtb Terms located at docs.usdtb.money and USDtb Mint User Agreement located at docs.usdtb.money.