NGUT Assists White Swan in ATTR White Paper Preparation

Challenge: MiCA Compliance for a Purely Speculative Asset

The White Swan project presented a unique challenge: making a "meme token" ($SWAN) – an asset explicitly stated to have no financial claims, governance rights, or inherent utility – MiCA-compliant for admission to trading. MiCA Title II demands rigorous disclosure, which typically focuses on the mechanics and financials of utility-bearing tokens. We needed to ensure investor protection through transparency, without misrepresenting the token's purely speculative nature.

NGUT’s Solution

We drafted the ATTR White Paper that made the token's speculative nature its defining feature:

1. Explicit No-Rights Disclosure: The White Paper clearly and repeatedly states that $SWAN's value is derived solely from community engagement and market perception.

2. Targeted Risk Warnings: We drafted specific risk disclosures emphasizing the high volatility and total dependence on speculation, moving beyond generic warnings to meet the spirit of MiCA's investor protection mandate.

Impact

The publication of the $SWAN ATTR White Paper is a pioneering step, potentially making it the first meme token to seek admission to trading under MiCA. This case study demonstrates NGUT’s ability to successfully apply the stringent MiCA disclosure framework to novel, non-utilitarian crypto-assets, setting a new standard for compliance in the decentralized finance space.

About NGUT

NGUT is a Finnish regulatory and technical consultancy focused on MiCA token consultancy with its specialty in offer to the public (OTPC) and admission to trading (ATTR) proceedings. Founded by the team behind the EU's first MiCA-compliant stablecoin, NGUT enables Web3 businesses to thrive under EU regulations.