Tokenized US Treasury funds look like onchain stablecoins, but their access rules are closer to a traditional broker-dealer's. Every major fund (BUIDL, OUSG, BENJI, USTB, USYC, USDY) routes new subscribers through a KYC and accreditation check that decides minimum ticket size, lock-up period, and which secondary venues a wallet can touch. The total tokenized-Treasury market crossed $11B in AUM by May 2026 per rwa.xyz, and the gating logic is what keeps it inside US securities law.
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This article maps the live KYC tiers across the six largest funds: who can subscribe, what minimum applies, which exemption (Reg D 506(c), Reg S, or non-registered) the issuer uses, which KYC provider handles onboarding, and how long the process actually takes. The data below is sourced from each issuer's offering documents, the SEC EDGAR filings linked at the bottom, and rwa.xyz issuer pages verified May 2026.
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Tokenized Treasury funds wrap a money-market or short-Treasury portfolio in a token whose transfer logic is gated by an allowlist. The issuer (or its transfer agent) only adds a wallet to the allowlist after the subscriber passes KYC, AML, sanctions screening, and (for US offerings) accredited-investor or qualified-purchaser verification. Without an allowlist entry, the token contract reverts on transfer, so peer-to-peer trading outside whitelisted venues is impossible by design.
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Three regulatory paths drive the differences below. Reg D 506(c) permits general solicitation to US accredited investors, who self-certify wealth or income and submit verification documents. Reg S covers offerings to non-US persons only and excludes US residents entirely. Qualified-purchaser offerings under Investment Company Act Section 3(c)(7) target investors with $5M+ in investments and skip retail entirely. Each path produces a different minimum ticket and a different onboarding queue. The SEC accredited-investor framework sets the income and net-worth thresholds the issuers verify against.
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Each fund's access tier is set by its offering exemption, its target investor base, and the transfer-agent infrastructure it uses. The table below summarizes minimums, eligibility, KYC provider, and typical onboarding time. AUM figures are from rwa.xyz as of May 2026.
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The pattern is clear. BUIDL sits at the institutional top with a $5M floor that filters down to a few hundred LPs. OUSG, USTB, and USYC cluster at the $100K accredited / qualified-purchaser tier, where most family offices and crypto-native funds operate. BENJI is the only fund of the six that accepts true retail through a registered 1940 Act structure. USDY exists in its own bucket: retail-accessible but only for non-US persons under Reg S.
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BlackRock's BUIDL (formally the BlackRock USD Institutional Digital Liquidity Fund) is offered exclusively to qualified purchasers under Investment Company Act Section 3(c)(7). The fund's SEC Form D filing confirms the qualified-purchaser limitation and the minimum investment of $5,000,000.
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Onboarding runs through Securitize, the SEC-registered transfer agent that issues the BUIDL token on Ethereum, Aptos, Arbitrum, Avalanche, Optimism, and Polygon. A subscriber creates a Securitize ID account, uploads identity documents (passport or driver's license plus proof of address), and submits qualified-purchaser verification (typically a letter from a CPA, attorney, or registered broker-dealer attesting to $5M+ in investments). Securitize routes AML and sanctions checks through Onfido and Chainalysis. Approved subscribers receive an allowlisted wallet address, and the token contract permits transfers only between whitelisted addresses.
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Typical onboarding takes 3 to 10 business days end to end. The bottleneck is qualified-purchaser verification, not the document upload. Investors with existing Securitize ID accounts from other private placements can compress this to 24 to 48 hours.
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Ondo's OUSG targets US accredited investors and qualified purchasers under Rule 506(c) and 3(c)(7). The minimum subscription is $100,000, and the fund holds a portfolio of short-duration Treasury ETFs (primarily BlackRock's SHV and the Ondo-managed underlying instruments). Per the Ondo OUSG product page, redemption settles in USDC within minutes during US market hours.
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KYC runs through Securitize ID, the same provider as BUIDL. The difference is the verification threshold: OUSG accepts accredited investors (defined by the SEC as $200K+ annual income, $300K with a spouse, or $1M+ net worth excluding primary residence), so the documentation queue is lighter than BUIDL's qualified-purchaser bar. Most subscribers complete onboarding in 2 to 5 business days. OUSG is also available on the Ondo Global Markets platform and through select prime brokers, which can pre-verify investors before the Securitize handoff.
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Franklin Templeton's BENJI is the tokenized share class of the Franklin OnChain US Government Money Fund (FOBXX), a 1940 Act registered fund. Because FOBXX is a registered investment company (not a private placement), it can be sold to US retail investors with no accreditation requirement, and the minimum is one share, currently priced at $1.00 per token. The fund's SEC filings on EDGAR document the registered structure and the share-class mechanics.
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Onboarding happens inside the Benji Investments mobile app. Subscribers create an account, link a US bank, complete identity verification (driver's license, SSN, address), and pass the standard CIP and AML checks Franklin runs on all FOBXX shareholders. Franklin's transfer agent records the share ownership and mirrors the position onchain as a BENJI token on Stellar, Polygon, Arbitrum, Avalanche, Base, or Ethereum. Onboarding typically completes in 1 to 3 business days, and the same KYC profile clears retail access to all of Franklin's other onchain money market share classes.
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Superstate's USTB (Superstate Short Duration US Government Securities Fund) is a Delaware statutory trust offered under 3(c)(7). The minimum subscription is $100,000 for qualified purchasers, and the fund holds short-duration Treasuries directly rather than through ETFs. Per Superstate's SEC Form D filings, USTB launched in early 2024 and has tracked steady AUM growth from institutional desks.
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Superstate handles KYC and accredited-investor verification in-house, with Parallel Markets as the underlying identity provider. Subscribers complete a Superstate onboarding flow that combines identity verification, qualified-purchaser certification, and entity documentation (LLC operating agreement, articles of incorporation for funds, trust documents for trusts). Approved subscribers wire USD or USDC to Superstate's transfer agent and receive USTB tokens directly to their whitelisted Ethereum address. Onboarding runs 2 to 7 business days, with entity subscriptions taking longer than individual ones.
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Hashnote's USYC (US Yield Coin) is a tokenized share of the Hashnote Short Duration Yield Fund, a 3(c)(7) qualified-purchaser fund. Circle's January 2025 acquisition of Hashnote made USYC the yield-bearing collateral inside Circle Mint, and the fund's AUM scaled to ~$3B by May 2026 per rwa.xyz. The Hashnote offering documents and the related SEC filings confirm the qualified-purchaser limitation.
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KYC runs through Hashnote's onboarding portal for direct subscribers, or through Circle Mint for institutions already onboarded with Circle. Circle's existing AML and KYC program (the same one used for USDC institutional minting) extends to USYC subscription, which compresses onboarding for Circle Mint clients from a typical 5 to 7 days to as little as 24 hours. Subscribers must still complete qualified-purchaser certification regardless of Circle Mint status. Settlement is in USDC, and redemption happens daily during US market hours.
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Ondo's USDY is the only fund of the six that targets retail users, and it does so by excluding US persons entirely. USDY is offered under Regulation S, which permits unregistered offerings to non-US persons without accreditation. There is no minimum subscription on the secondary market (USDY trades on Bybit, Bitget, and several DEXs), and the primary-market minimum at Ondo is $500.
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KYC for direct subscription runs through Ondo's onboarding (powered by Sumsub), which verifies identity, jurisdiction (rejecting US, sanctioned-country, and other excluded jurisdictions like Canada and the UK), and source-of-funds. Approved subscribers receive USDY on Ethereum, Solana, Mantle, Sui, Aptos, Cosmos (via Noble), or Arbitrum. Onboarding typically completes in 1 to 4 business days. The token uses a rebasing mechanism: balances grow daily to reflect Treasury yield, so holders see USDY appreciate rather than receiving separate yield distributions. The USDY documentation covers the full subscription path and the jurisdiction list.
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A qualified purchaser is an investor with $5,000,000 or more in investments (for individuals and family offices) or $25,000,000 or more in investments managed on a discretionary basis (for institutions). The category is defined in Investment Company Act Section 2(a)(51) and is a higher bar than "accredited investor". Qualified-purchaser funds (3(c)(7)) can have up to 2,000 investors before they trigger registration under the Investment Company Act, which is why most tokenized institutional Treasury funds use this structure.
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The verification mechanics are similar to accredited-investor verification (third-party letter from a CPA, attorney, or registered investment adviser), but the threshold is $5M in investments, not net worth or income. Primary residence, business equity in a closely held business, and consumer goods do not count toward the $5M. Securitize, Parallel Markets, and the issuers' own teams all use the same documentation standards.
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Three providers dominate the tokenized Treasury KYC stack as of 2026. Securitize is the largest: BUIDL and OUSG both route through Securitize ID, and Securitize is the registered transfer agent for several smaller funds as well. Parallel Markets handles identity for Superstate's USTB and acts as a portable accreditation layer that several smaller issuers accept. Sumsub handles Ondo's USDY (and many of Ondo's other retail-facing products), with its strength being non-US jurisdiction screening. Hashnote runs in-house KYC for direct subscribers but inherits Circle's institutional KYC when subscribed through Circle Mint.
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The portable-accreditation thesis (one verification, used across many issuers) is real but incomplete. A Securitize ID verified for BUIDL can subscribe to OUSG without re-verification, but cannot subscribe to USTB without re-running through Parallel Markets. Each issuer's transfer agent is the ultimate gatekeeper, so verification portability stops at the issuer boundary.
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BENJI is the fastest (1 to 3 business days), driven by the streamlined retail CIP/AML check that Franklin runs across all FOBXX share classes. USDY follows at 1 to 4 days for non-US subscribers. OUSG, USYC, and USTB cluster at 2 to 7 business days for first-time qualified-purchaser verification. BUIDL is the longest, 3 to 10 days, because the $5M minimum forces a deeper source-of-funds review and (for non-US qualified purchasers) additional cross-border AML checks.
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For institutions onboarding multiple funds at once, the time-to-first-trade is dominated by entity documentation, not identity verification. LLC operating agreements, trust documents, and authorized-signer letters typically add 2 to 5 business days regardless of which fund is targeted. The fastest institutional onramp is BENJI through an existing brokerage relationship, where the broker has already KYC'd the entity.
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AUM figures are pulled from rwa.xyz verified May 2026. Minimum subscription, eligibility, and exemption details come from each issuer's offering documents and SEC EDGAR filings linked below. Onboarding-time ranges are typical retail and institutional intake times reported by the issuers and KYC providers; entity-level subscriptions and non-US subscribers may run longer. Yield numbers (referenced in the per-fund sections) come from each issuer's official disclosure pages. This article is education-only and is not investment advice or a solicitation. Always confirm current terms directly with the issuer before subscribing.
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