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Regulatory Considerations

For questions about this assessment, contact legal@alxlabs.io.

Applicable U.S. Regulatory Framework​

On March 17, 2026, the U.S. Securities and Exchange Commission (SEC) and the Commodity Futures Trading Commission (CFTC) jointly issued Interpretive Release No. 33-11412; 34-105020, effective March 23, 2026. Read the SEC release.

The release describes a taxonomy for crypto assets:

  • Digital Commodity
  • Digital Tool
  • Digital Collectible
  • Stablecoin
  • Digital Security

Digital commodities, digital collectibles, and digital tools are not themselves securities, though they may be offered and sold subject to an investment contract, which is a security.

Digital Tool Characteristics​

The XNDR token exhibits characteristics consistent with the category of a Digital Tool under the SEC/CFTC framework:

  • The XNDR token is designed to provide practical utility across XNDR Network services built on ALX Protocol data.
  • The XNDR token is intended to provide access to eligible network services and participation programs as they are released.
  • The XNDR token functions as the unit for developer incentives, governance participation, and ecosystem funding.
  • The XNDR token is intended to function as a network access token rather than as a representation of ownership, equity, or revenue rights in ALX Labs, LLC.

Digital Commodity Characteristics​

The XNDR token also exhibits characteristics consistent with the category of a Digital Commodity under the SEC/CFTC framework:

  • The XNDR token is linked to the programmatic operation of XNDR Network services, not to ALX Protocol conformance.
  • The XNDR token's value may be influenced by supply and demand dynamics and network usage, rather than by managerial efforts.
  • ALX Protocol is independently usable as an open technical standard.
  • XNDR Network uses the XNDR token for contribution rewards, treasury funding, ecosystem programs, and governance participation.
  • The XNDR token is not required for ALX Protocol conformance or Block validity.

Preliminary Assessment​

TopicValue
Regulatory ClassificationDigital Tool / Digital Commodity characteristics
Public Presale Allocation1.5B XNDR / 15%
Token Sale Schedule25% at TGE; six-month cliff; linear vesting over 24 months to Month 30