MSTR Cat

Crypto Law/Level VI · Market conduct/6.3 The honest launch/Lesson 4

Treasury and team wallets in public

How to identify and describe a project’s treasury and insiders’ wallets so buyers can see who holds what, who can move it, and what the contracts really restrict.

Education, not legal, tax or investment advice. Crypto law differs between countries and states and changes often. Check the current rules where you live with a qualified lawyer or tax adviser before you act.

The lean path

The cheapest, lowest-tax, simplest and most private route the law allows, best first. Each step names the rule it rests on and the condition that keeps it lawful.

  1. Zero-cost: publish a wallet register by role, listing amounts at launch, controller, approval rules and sale restrictions. Labelling by role rather than name keeps lawful privacy. Catch: omitting an insider wallet creates the half-truth problem.
  2. Hold the treasury in a Safe multisig, free apart from gas, and disclose threshold, signer count and roles. Catch: a low threshold such as one-of-three gives little protection and must be described plainly.
  3. Vest team tokens through a contract such as OpenZeppelin’s VestingWallet, and disclose that its ownership is transferable unless an agreement restricts it, so unvested tokens can in effect be sold. Catch: tokens sent after vesting starts are partly releasable at once.
  4. Publish a sales policy for insider wallets in advance and follow it, turning sales into expected events and reducing insider-dealing risk, including under MiCA Article 89 for admitted tokens. SafeMoon’s executives denied trading while trading.
  5. Give the treasury a legal owner, such as an entity, instead of founders’ personal wallets, avoiding commingling and partnership liability; formation fees are worth paying once the treasury is material. Catch: the owner still reports and pays tax on treasury income.

MaterialsA register of every treasury, team, adviser and vesting address, with its purposeThe multisig or vesting contract settings, read from a block explorerOpenZeppelin’s VestingWallet documentationLesson 5.1.2, on team allocations, vesting and disclosure

Wonder

  1. Do I have to tell people which wallets belong to the team?
  2. If tokens sit in a vesting contract, can they really not be sold?
  3. Is a project treasury the founders’ money?

Explore

  1. Buyers of a new token carry one risk above all: that insiders hold a large share and will sell it. Lesson 5.1.2 covers how allocations are taxed and what the proposed Regulation Crypto Assets would require issuers to disclose about related persons’ holdings and transfer restrictions. This lesson is about making those holdings visible. The SafeMoon case shows the stakes. According to federal prosecutors, executives publicly denied that they personally held or traded the token while repeatedly buying and selling it, and chief executive Braden John Karony was sentenced on 10 February 2026 to 100 months in prison.
  2. A useful wallet register lists, for each address, its role (treasury, operations, team, advisers, market making, exchange listings), the amount held at launch, who controls it, how transactions are approved, and any restriction on selling. Labelling wallets by role rather than by personal name can balance privacy with clarity (lesson 6.3.3). The register should cover wallets that receive tokens later, such as contracts paying out vested amounts, because those are where sales usually start. A register that omits a wallet later found to belong to an insider is the half-truth problem from lesson 6.3.1.
  3. How a treasury is controlled matters as much as how much it holds. A single private key means one person can move everything, and one lost or stolen key can lose it. Safe’s documentation describes smart accounts that execute a transaction only when a set threshold of owners has confirmed it, a threshold that can be anywhere from one to all owners. A one-of-three Safe is, in practice, three single keys. Disclosing the threshold, the number of signers and their roles, and whether any signer is outside the team, lets buyers judge what ‘held by the multisig’ means.
  4. Vesting contracts restrict less than they appear to. OpenZeppelin’s VestingWallet releases assets to a beneficiary on a schedule, linear by default. But its documentation warns that because the wallet is ownable, ownership can be transferred, so unvested tokens can in effect be sold by transferring the contract. It also notes that tokens sent to a vesting wallet after vesting has begun are at least partly releasable at once. A claim that team tokens are ‘vested on-chain’ should therefore say which contract holds them, its schedule, whether ownership can be transferred, and whether any agreement outside the code also restricts sales.
  5. Sales from insider wallets raise their own legal questions. In the US, trading ahead of confidential token news has already produced both SEC insider-trading charges and parallel criminal charges, in the case of a former Coinbase product manager (lesson 6.2.2). In the EU, MiCA Article 89 prohibits insider dealing in crypto-assets that are admitted to trading or for which admission has been requested. Insider sales during a period when the team is promoting its own work also bear on whether buyers rely on that team (lesson 3.1.4). Publishing a sales policy in advance, and then following it, turns a suspicious transfer into an expected one.
  6. A treasury also needs a legal owner. Tokens held for a project are not automatically the founders’ personal property, and mixing project funds with personal ones was central to the FTX collapse (lesson 4.1.3). Without an entity, the people running a treasury risk being treated as partners who share liability for it (lesson 5.3.4), and the tax treatment of treasury income depends on who owns it (lesson 5.3.7). A practical check: for each wallet in the register, name the legal owner, the people who can sign, any restriction on sales and where a buyer can verify each point.

Key facts

  • Federal prosecutors said SafeMoon executives publicly denied holding or trading the token while repeatedly buying and selling it.
  • Former SafeMoon CEO Braden John Karony was sentenced on 10 February 2026 to 100 months in prison and ordered to forfeit about $7.5 million.
  • A Safe smart account’s threshold can be set anywhere from one to the total number of its owners.
  • OpenZeppelin’s VestingWallet releases assets to its beneficiary on a schedule that is linear by default.
  • OpenZeppelin warns that because a VestingWallet’s ownership can be transferred, unvested tokens can in effect be sold.
  • MiCA Article 89 prohibits insider dealing in crypto-assets admitted to trading or for which a request for admission has been made.

Exercise nine, six, three, one

9CollectList up to 9 wallets or contracts that hold tokens for insiders or a project treasury in a launch you know or are planning (some lists are shorter).
6ClusterSort them into 6 categories: treasury, operations, team, advisers or promoters, market making or listings, and wallets whose role is unclear.
3DistillReduce the 6 categories to 3 groups: wallets that are published with controls explained, wallets that are published without controls explained, and wallets that are not published.
1CrystallizeWrite 1 sentence describing who can move the largest insider or treasury balance on your list, and what, if anything, would stop them.

Fact check

Dates, figures and claims checked against the published sources listed below.

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