ADGM position

The legal work is done against operative text, fetched and hashed, not against summaries. Ten documents are in the source registry with SHA-256 hashes and recorded effective dates.

Where each instrument stands

drUSD is a fiat-referenced token. The classification is mechanical on sourced text — it is derived, not assumed. What remains is the permission grant and ongoing compliance, both named precisely rather than waved at.

sdrUSD meets the collective-investment-fund definition mechanically, so it is a Unit. The route is the qualified-investor fund: private placement only, all holders professional clients, a minimum subscription, and notification rather than registration. The blocker is the fund-manager permission — and in this framework naming the exact missing permission is a resolved outcome, not an open question.

The secondary venue turns on a recognition order. Operating a protocol-owned venue is a regulated activity in its own right, and the issuer may not operate one at all.

The honest headline

Superseded — read this first. An earlier version of this page said no architecture is legally feasible today, unconditionally. That statement was scoped to the L1 fixture over unsourced law and is no longer the operative result: dore_ceiling_v020 proves the baseline passes the sourced-law gate, subject to an Accepted-FRT determination that has not been sought. The paragraph below is retained because the reasoning still applies to any design whose classification is unresolved.

No architecture was legally feasible on the unsourced fixture, for every design in the grammar. The classification questions are answered; the permissions are not held. That theorem exists specifically so that no amount of optimization can quietly assume the problem away.

See Sourced provisions for the specific rules.