Florian
344 posts

Florian
@floowp_
general counsel @chroniclelabs | co-founder @DeFiCollective_ and @defiscan_info








Working my way through the new SEC and CFTC interpretive guidance and I'm loving footnote 96. Why? In many ways FN96 explains the core approach: earlier in the guidance we are told that tokens whose value comes from functionality and supply/demand rather than essential managerial efforts of a promoter are not securities. But how do you define functionality and a lack of managerial efforts (i.e. decentralization) post ICO...? Not by some technocratic general standard! But rather by the actual promises of the original promoters (and whether they've been satisfied or otherwise extinguished). A very Hayekian approach that avoids regulatory hubris and metaphysical wrangling over the nature of "functionality" or "decentralization." Well done.

not so convinced earlier in the guidance (p 27), SEC actually (accidentally or not) incentives to not disclose basic project info (business plan, milestones, funding, etc.) reads as though you're still better of disclosing less than more, even if you can set your own standards


Truth is onchain.

Chronicle now provides Proof of Asset verification for @Securitize’s Tokenized AAA CLO Fund (STAC). STAC is a tokenized fund that aims to invest substantially all of the fund’s assets in U.S. dollar‑denominated AAA‑rated CLO tranches from both the primary and secondary markets.


We’ve integrated @ChronicleLabs as the Proof of Asset verification layer for the Securitize Tokenized AAA CLO Fund (STAC). This enables continuous, independently verifiable transparency into the fund’s holdings and valuation inputs.



Particula assigns a AAA rating* to the issuance of Janus Henderson Anemoy AAA CLO Fund Token ($JAAA) as of November 5, 2025. The JAAA token represents shares in a segregated portfolio issued by (@anemoycapital) Anemoy Capital SPC Limited and provides investment exposure primarily in AAA-rated tranches of Collateralized Loan Obligations (CLOs). Anemoy Asset Management Limited acts as the Investment Manager, with (@JHIAdvisors) Janus Henderson Investors U.S. LLC appointed as Sub-Investment Manager. 👇Download full report here: particula.io/rating-reports… __ *𝘋𝘪𝘴𝘤𝘭𝘢𝘪𝘮𝘦𝘳: 𝘛𝘩𝘦 𝘪𝘯𝘧𝘰𝘳𝘮𝘢𝘵𝘪𝘰𝘯 𝘢𝘯𝘥 𝘢𝘯𝘢𝘭𝘺𝘴𝘦𝘴 𝘳𝘦𝘭𝘢𝘵𝘦𝘥 𝘵𝘰 𝘤𝘳𝘺𝘱𝘵𝘰 𝘷𝘢𝘭𝘶𝘦𝘴, 𝘤𝘳𝘺𝘱𝘵𝘰 𝘵𝘰𝘬𝘦𝘯𝘴, 𝘢𝘯𝘥 𝘰𝘵𝘩𝘦𝘳 𝘥𝘪𝘨𝘪𝘵𝘢𝘭 𝘢𝘴𝘴𝘦𝘵𝘴 (“𝘋𝘪𝘨𝘪𝘵𝘢𝘭 𝘈𝘴𝘴𝘦𝘵𝘴“) 𝘱𝘳𝘰𝘷𝘪𝘥𝘦𝘥 𝘣𝘺 𝘗𝘢𝘳𝘵𝘪𝘤𝘶𝘭𝘢 𝘎𝘮𝘣𝘏 (“𝘗𝘢𝘳𝘵𝘪𝘤𝘶𝘭𝘢“) 𝘢𝘳𝘦 𝘦𝘹𝘤𝘭𝘶𝘴𝘪𝘷𝘦𝘭𝘺 𝘮𝘢𝘥𝘦 𝘢𝘷𝘢𝘪𝘭𝘢𝘣𝘭𝘦 𝘵𝘰 𝘦𝘯𝘵𝘳𝘦𝘱𝘳𝘦𝘯𝘦𝘶𝘳𝘴 𝘸𝘪𝘵𝘩𝘪𝘯 𝘵𝘩𝘦 𝘮𝘦𝘢𝘯𝘪𝘯𝘨 𝘰𝘧 § 14 𝘉𝘎𝘉 𝘢𝘯𝘥 𝘢𝘳𝘦 𝘪𝘯𝘵𝘦𝘯𝘥𝘦𝘥 𝘴𝘰𝘭𝘦𝘭𝘺 𝘧𝘰𝘳 𝘪𝘯𝘧𝘰𝘳𝘮𝘢𝘵𝘪𝘰𝘯𝘢𝘭 𝘱𝘶𝘳𝘱𝘰𝘴𝘦𝘴. 𝘛𝘩𝘦 𝘱𝘳𝘰𝘷𝘪𝘥𝘦𝘥 𝘪𝘯𝘧𝘰𝘳𝘮𝘢𝘵𝘪𝘰𝘯 𝘢𝘯𝘥 𝘢𝘯𝘢𝘭𝘺𝘴𝘦𝘴 𝘥𝘰 𝘯𝘰𝘵 𝘤𝘰𝘯𝘴𝘵𝘪𝘵𝘶𝘵𝘦 𝘢 𝘳𝘢𝘵𝘪𝘯𝘨 𝘢𝘴 𝘥𝘦𝘧𝘪𝘯𝘦𝘥 𝘪𝘯 𝘈𝘳𝘵. 3 𝘱𝘢𝘳𝘢. 1 𝘭𝘪𝘵. 𝘢) 𝘰𝘧 𝘙𝘦𝘨𝘶𝘭𝘢𝘵𝘪𝘰𝘯 𝘌𝘎/1060/2009 (“𝘙𝘢𝘵𝘪𝘯𝘨 𝘙𝘦𝘨𝘶𝘭𝘢𝘵𝘪𝘰𝘯“). 𝘈 𝘤𝘳𝘦𝘥𝘪𝘵𝘸𝘰𝘳𝘵𝘩𝘪𝘯𝘦𝘴𝘴 𝘢𝘴𝘴𝘦𝘴𝘴𝘮𝘦𝘯𝘵 𝘢𝘴 𝘥𝘦𝘧𝘪𝘯𝘦𝘥 𝘪𝘯 𝘈𝘳𝘵. 3 𝘱𝘢𝘳𝘢. 1 𝘭𝘪𝘵. 𝘢) 𝘰𝘧 𝘵𝘩𝘦 𝘙𝘢𝘵𝘪𝘯𝘨 𝘙𝘦𝘨𝘶𝘭𝘢𝘵𝘪𝘰𝘯, 𝘦𝘷𝘢𝘭𝘶𝘢𝘵𝘪𝘯𝘨 𝘵𝘩𝘦 𝘪𝘴𝘴𝘶𝘦𝘳’𝘴 𝘤𝘳𝘦𝘥𝘪𝘵𝘸𝘰𝘳𝘵𝘩𝘪𝘯𝘦𝘴𝘴, 𝘪𝘴 𝘦𝘹𝘱𝘳𝘦𝘴𝘴𝘭𝘺 𝘯𝘰𝘵 𝘱𝘢𝘳𝘵 𝘰𝘧 𝘵𝘩𝘦 𝘢𝘯𝘢𝘭𝘺𝘴𝘪𝘴.







