Regulatory Considerations
Legal Notice
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
| Topic | Value |
|---|---|
| Regulatory Classification | Digital Tool / Digital Commodity characteristics |
| Public Presale Allocation | 1.5B XNDR / 15% |
| Token Sale Schedule | 25% at TGE; six-month cliff; linear vesting over 24 months to Month 30 |