Annerton advised Stokr on all DLT and regulatory issues in its application for BaFin permission for a Bitcoin-blockchain-based Security Token Offering (STO) for video game provider Exordium. On 17 September 2021, the STO was officially approved by BaFin, which is unique in using a Liquid Blockchain and issuing in security token, instead of the previously used Etherum-blockchain. The investment platform Stokr has been offering token-based financial products to retail and institutional investors since 2017.
As of now, German retail investors can participate in the so-called EXOeu offering by Exordium on Stokr. Exordium Games is the publisher of the science fiction video game “Infinite Fleet”, in which several million euros have already been invested and can now be used as an asset investment for retail investors through a bitcoin-blockchain-based security token offering.
The approval of the application is special in the crypto scene for several reasons. So far, BaFin has only approved STOs issued on the Etherum-blockchain. The development of an STO on a liquid blockchain (a sidechain of the Bitcoin blockchain) and the permission for a cross-border distribution of securities-like tokens with a securities information sheet that has already been prepared in compliance with eWpG is also a novelty.
For the permission procedure, Annerton partner Alireza Siadat worked shoulder-to-shoulder with lawyer Ulrich Reers of Taylor Wessing and in-house lawyers Tobias Seidl and Gabriella Gojani. Alireza advised Stokr on all specific questions regarding regulatory law and the so-called DLT (Distributed Ledger Technology) issues.
Annerton is an independent law firm specialising in regulatory law in the financial industry. Since 2020, Annerton Rechtsanwaltsgesellschaft mbH in Germany and Annerton S.A. in Luxembourg have been advising established international institutions and corporations as well as innovative start-ups from the banking, financial services and digital economy sectors. Annerton is present at four locations in Berlin, Frankfurt am Main, Munich and Luxembourg with currently 19 lawyers, a tax advisor and other team members.