
| N° | FIELD | CONTENT |
|---|---|---|
| 00 | Table of Content | 00 Table of Content 01 Date of Notification 02 Statement in Accordance with Article 6 (3) of Regulation (EU) 2023/1114 03 Statement in Accordance with Article 6 (6) of Regulation (EU) 2023/1114 04 Statement in Accordance with Article 6 (5) points (a), (b), (c) of Regulation (EU) 2023/1114 05 Statement in Accordance with Article 6 (5), point (d) of Regulation (EU) 2023/1114 06 Statement in Accordance with Article 6 (5), points (e) and (f) of Regulation (EU) 2023/1114 SUMMARY 07 Warning in Accordance with Article 6 (7), second subparagraph of Regulation (EU) 2023/1114 08 Characteristics of the Crypto-Asset 09 Information about the Quality and Quantity of Goods or Services to which the Utility Tokens Give Access and Restrictions on the Transferability. 10 Key Information about the Admission to Trading PART I – INFORMATION ON RISKS I.01 Admission to Trading-Related Risks I.02 Issuer-Related Risks I.03 Crypto-Assets-Related Risks I.04 Project Implementation-Related Risks I.05 Technology-Related Risks I.06 Mitigation Measures PART A – INFORMATION ABOUT THE offer or OR THE PERSON SEEKING ADMISSION TO TRADING A.01 Name A.02 Legal Form A.03 Registered Address A.04 Head Office A.05 Registration Date A.06 Legal entity Identifier A.07 Another Identifier Required Pursuant to Applicable National Law A.08 Contact Telephone Number A.09 E-mail Address A.10 Response Time (Days) A.11 Parent Foundation A.12 Members of the Management body A.13 Business Activity A.14 Parent Foundation Business Activity A.15 Newly Established A.16 Financial Condition for the Past Three Years A.17 Financial Condition since Registration PART B – INFORMATION ABOUT THE ISSUER, IF DIFFERENT FROM THE offer or OR PERSON SEEKING ADMISSION TO TRADING B.01 Issuer different from offer or or Person Seeking Admission to Trading B.02 Name B.03 Legal Form B.04 Registered Address B.05 Head Office B.06 Registration Date B.07 Legal Entity Identifier B.08 Another Identifier Required Pursuant to Applicable National Law B.09 Parent Foundation B.10 Members of the Management Body B.11 Business Activity B.12 Parent Foundation Business Activity PART C – INFORMATION ABOUT THE OPERATOR OF THE TRADING PLATFORM IN CASES WHERE IT DRAWS UP THE CRYPTO-ASSET WHITE PAPER AND INFORMATION ABOUT OTHER PERSONS DRAWING THE CRYPTO-ASSET WHITE PAPER PURSUANT TO ARTICLE 6(1), SECOND SUBPARAGRAPH, OF REGULATION (EU) 2023/1114 C.01 Name C.02 Legal Form C.03 Registered Address C.04 Head Office C.05 Registration Date C.06 Legal Entity Identifier of the Operator of the Trading Platform C.07 Another Identifier Required Pursuant to Applicable National Law C.08 Parent Foundation C.09 Reason for Crypto-Asset White Paper Preparation C.10 Members of the Management Body C.11 Operator Business Activity C.12 Parent Foundation Business Activity C.13 Other Persons Drawing up the Crypto Asset White Paper According to Article 6 (1), Second Subparagraph, of Regulation (EU) 2023/1114 C.14 Reason for Drawing the White Paper by Persons Referred to in Article 6 (1), Second Subparagraph, of Regulation (EU) 2023/1114 PART D – INFORMATION ABOUT THE CRYPTO-ASSET PROJECT D.01 Crypto-Asset Project Name D.02 Crypto-Assets Name D.03 Abbreviation D.04 Crypto-Asset Project Description D.05 Details of all Natural or Legal Persons Involved in the Implementation of the Crypto-Asset Project D.06 Utility Token Classification D.07 Key Features of Goods/Services for Utility Token Projects D.08 Plans for the Token D.09 Resource Allocation D.10 Planned Use of Collected Funds or Crypto-Assets PART E – INFORMATION ABOUT THE OFFER TO THE PUBLIC OF CRYPTO-ASSETS OR THEIR ADMISSION TO TRADING E.01 Admission to Trading E.02 Reasons for the Admission to Trading E.03 Fundraising Target E.04 Minimum Subscription Goals E.05 Maximum Subscription Goal E.06 Oversubscription Acceptance E.07 Oversubscription Allocation E.08 Issue Price E.09 Official Currency or any other Crypto-Assets Determining the Issue Price E.10 Subscription Fee E.11 Offer Price Determination Method E.12 Total Number of Traded Crypto-Asset E.13 Targeted Holders E.14 Holder Restrictions E.15 Reimbursement Notice E.16 Refund Mechanism E.17 Refund Timeline E.18 Offer Phases E.19 Early Purchase Discount E.20 Time-Limited Offer E.21 Subscription Period Beginning E.22 Subscription Period End E.23 Safeguarding Arrangements for Offered Funds/Crypto-Assets E.24 Payment Methods for Crypto-Asset Purchase E.25 Value Transfer Methods for Reimbursement E.26 Right of Withdrawal E.27 Transfer of Purchased Crypto-Assets E.28 Transfer Time Schedule E.29 Purchaser's Technical Requirements E.30 Crypto-asset service provider (CASP) name E.31 CASP Identifier E.32 Placement Form E.33 Trading Platforms Name E.34 Trading Platforms Market Identifier Code (MIC) E.35 Trading Platforms Access E.36 Involved Costs E.37 Offer Expenses E.38 Conflicts of Interest E.39 Applicable Law E.40 Competent Court PART F – INFORMATION ABOUT THE CRYPTO-ASSET F.01 Crypto-Asset Type F.02 Crypto-Asset Functionality F.03 Planned Application of Functionalities F.04 Type of White Paper F.05 The type of Submission F.06 Crypto-Asset Characteristics F.07 Commercial Name or Trading Name F.08 Website of the Issuer F.09 Starting date of Offer to the Public or Admission to Trading F.10 Publication Date F.11 Any other Services Provided by the Issuer F.12 Identifier of Operator of the Trading Platform F.13 Language or Languages of the White Paper F.14 Digital Token Identifier Code used to Uniquely Identify the Crypto-Asset or Each of the Several Crypto Assets to which the White Paper Relates, Where Available F.15 Functionally Fungible Group Digital Token Identifier, where available F.16 Voluntary Data Flag F.17 Personal data Flag F.18 LEI Eligibility F.19 Home Member State F.20 Host Member States PART G – INFORMATION ON RIGHTS AND OBLIGATIONS ATTACHED TO THE CRYPTO-ASSETS G.01 Purchaser Rights and Obligations G.02 Exercise of Rights and Obligations G.03 Conditions for Modifications of Rights and Obligations G.04 Future Public Offers G.05 Issuer Retained Crypto-Assets G.06 Utility Token Classification G.07 Key Features of Goods/Services of Utility Tokens G.08 Utility Tokens Redemption G.09 Non-Trading Request G.10 Crypto-Assets Purchase or Sale Modalities G.11 Crypto-Assets Transfer Restrictions G.12 Supply Adjustment Protocols G.13 Supply Adjustment Mechanisms G.14 Token Value Protection Schemes G.15 Token Value Protection Schemes Description G.16 Compensation Schemes G.18 Applicable Law G.19 Competent Court PART H – INFORMATION ON THE UNDERLYING TECHNOLOGY H.01 Distributed Ledger Technology H.02 Protocols and Technical Standards H.03 Technology Used H.04 Consensus Mechanism H.05 Incentive Mechanisms and Applicable Fees H.06 Use of Distributed Ledger Technology H.07 DLT Functionality Description H.08 Audit H.09 Audit Outcome PART J – INFORMATION ON THE SUSTAINABILITY INDICATORS IN RELATION TO ADVERSE IMPACT ON THE CLIMATE AND OTHER ENVIRONMENT-RELATED ADVERSE IMPACTS J.01 Adverse Impacts on Climate and Other Environment-Related Adverse Impacts S.02 Name S.03 Relevant Legal Entity Identifier S.04 Name of the Crypto-Asset S.05 Consensus Mechanism S.06 Incentive Mechanisms and Applicable Fees S.07 Beginning of the Period to which the Disclosure Relates S.08 End of the Period to which the Disclosure Relates S.09 Energy Consumption S.10 Energy Consumption Sources and Methodologies |
| 01 | Date of Notification | August 15, 2025. |
| 02 | Statement in Accordance with Article 6(3) of Regulation (EU) 2023/1114 | ‘This crypto-asset white paper has not been approved by any competent authority in any Member State of the European Union. The offer or of the crypto-asset is solely responsible for the content of this crypto-asset white paper.’ |
| 03 | Compliance statement in Accordance with Article 6(6) of Regulation (EU) 2023/1114 | ‘This crypto-asset white paper complies with Title II of Regulation (EU) 2023/1114 and, to the best of the knowledge of the management body, the information presented in the crypto-asset white paper is fair, clear and not misleading and the crypto- asset white paper makes no omission likely to affect its import.’ |
| 04 | Statement in Accordance with Article 6(5), points (a), (b), (c) of Regulation (EU) 2023/1114 | ‘The crypto-asset referred to in this white paper may lose its value in part or in full, may not always be transferable and may not be liquid.’ |
| 05 | Statement in Accordance with Article 6(5), point (d) of Regulation (EU) 2023/1114 | ‘The utility token referred to in this white paper may not be exchangeable against the good or service promised in the crypto-asset white paper, especially in the case of a failure or discontinuation of the crypto-asset project.’ |
| 06 | Statement in Accordance with Article 6(5), points (e) and (f) of Regulation (EU) 2023/1114 | ‘The crypto-asset referred to in this white paper is not covered by the investor compensation schemes under Directive 97/9/EC of the European Parliament and of the Council. The crypto-asset referred to in this white paper is not covered by the deposit guarantee schemes under Directive 2014/49/EU of the European Parliament and of the Council.’ |
| SUMMARY | ||
| 07 | Warning in accordance with Article 6(7), second subparagraph of Regulation (EU) 2023/1114 | ‘WARNING This summary should be read as an introduction to the crypto-asset white paper. The prospective holder should base any decision to purchase this crypto-asset on the content of the crypto-asset white paper as a whole and not on the summary alone. The admission to trading of this crypto-asset does not constitute an offer or solicitation to purchase financial instruments, or an admission to trading of financial instruments and any such offer, solicitation or admission can be made only by means of a prospectus or other offer documents pursuant to the applicable national law. This crypto-asset white paper does not constitute a prospectus as referred to in Regulation (EU) 2017/1129 of the European Parliament and of the Council or any other offer document pursuant to Union or national law.’ |
| 08 | Characteristics of the Crypto-Asset | The crypto-asset referred to in this white paper is the BARD token (“Token”). The Token is the governance token of the Lombard Protocol (“Protocol”) – a technical infrastructure offering DeFi products and services around Bitcoin (“BTC”). The Token is required to access the governance mechanism of the Protocol. |
| 09 | Key Information about the Quality and Quantity of the Goods or Services to which the Utility Token give Access Restrictions on Transferability. | By holding the Token, Token holders can: Participate in the Protocol Governance: The purpose of the governance functionality of the Token is to create a stable and trustworthy ecosystem by allowing Token holders to access and participate in the decentralized, balanced ecosystem consensus mechanism. Protocol Governance: Token holders can adjust certain parameters of the Protocol and vote on Protocol upgrades; and Protocol Security: Token holders can vote on the composition of the Security Consortium (as defined in D.04). Token holders only participate in technical and/or operational decision-making but have no influence over the corporate governance of the offer or / person seeking admission to trading, or any other party of the Protocol ecosystem. The Tokens to be admitted to trading (see E12) are freely transferable. |
| 10 | Key Information about the Admission to Trading | Liquid Bitcoin Foundation (“Foundation”) seeks admission of the Token on trading platforms operating within the European Union (“EU”) or the European Economic Area (“EEA”) (“Trading Platforms”). |
| PART I – INFORMATION ON THE RISKS | ||
| I.01 bis | Admission to Trading-Related Risks | No Listing Risk: The present white paper is drafted and notified by the Foundation in accordance with its obligations under Article 5 of MiCA, in its capacity as a person seeking the admission of the Token to trading. As of the date of notification, listing and trading of the Token has not been confirmed to take place on any Trading Platforms. The Foundation, its affiliates, directors, and officers shall not be held liable for any damages, losses, costs, fines, penalties, or expenses of any kind – whether or not reasonably foreseeable by the Foundation or the potential Token holder – that the potential Token holder may suffer, sustain, or incur in connection with, or as a result of, the Token not being listed on a Trading Platform. General Contractual and Counterparty Risk: The Foundation neither operates nor controls, oversees, or manages the functioning of (i) crypto-asset services providers as defined under MiCA (“CASP”) operating within the EU/EEA and (ii) Trading Platforms (together with CASPs, the “Exchanges”) where the Token will be admitted for trading or listed. When potential Token holders buy or sell the Token on Exchanges, the Foundation is not a contractual party to these transactions. As a result: Any legal relationship between potential Token holders and the Exchanges is governed solely by the terms and conditions set by each Exchanges at its discretion. The Foundation assumes no responsibility or liability for the operations, services, security, performance, or any outcomes – whether financial or technical – arising from transactions conducted on these Exchanges. The Foundation provides no assurances regarding any Exchanges itself and assumes no responsibility or liability for any regulatory, compliance, operational, financial, technical, or reputational failures that may adversely affect its activities. This includes, but is not limited to, circumstances where such failures result in disruptions, restrictions on trading, or the Exchanges halting or ceasing its operations entirely, due to sanctions, bankruptcy or alike. The foregoing may result in substantial or even total losses for the potential Token holder. Spontaneous Admission to Trading Risk by Trading Platform: Third parties can elect to admit the Token on their Trading Platforms without any request, authorization or approval by the Foundation or anyone else. Pursuant to article 5 (2) of MiCA, Trading Platforms are responsible for ensuring compliance with all applicable laws, especially MiCA requirements with respect to the spontaneous admission of the Token to trading. The Foundation, its affiliates, directors, and officers shall not be held liable for these spontaneous admissions to trading. Multiple White Paper Risk: Token holders understand that any third party can decide to draft and publish a MiCA white paper about the Token (“Spontaneous White Paper”). The publication of these Spontaneous White Papers does not imply any endorsement by the Foundation that the Spontaneous White Papers are complete, correct, fair, clear and not misleading. Pausing and Delisting Risk: The Foundation cannot guarantee that the Token will remain listed or tradeable on any Exchanges. Delisting (or the temporary pausing of such listing) could significantly hinder the ability of potential Token holders to buy, sell, or otherwise transact in the Token. In the event of delisting, potential Token holders may face challenges in finding alternative markets or counterparties willing to trade Tokens, which could adversely impact the Token’s liquidity and market value. Delisting could also negatively impact the price of the Token, due to modified demand for the Token and/or reputational impact. Trading Risk: The Foundation does not control the secondary markets. There can be no assurance as to the secondary market (if any) in the Token, and specifically: It cannot guarantee the depth, stability, or sustainability of any secondary market for the Token. Limited market depth or trading activity may result in reduced liquidity, increased price volatility, and challenges in buying or selling Tokens at desired prices. It cannot guarantee the healthy and consistent availability of buying or selling opportunities for the Token or the integrity of their market price. Trading activity may be affected by manipulative practices such as wash trading, frontrunning, and similar schemes. While Exchanges are subject to varying regulatory frameworks that may or may not prohibit such practices and impose oversight to detect and deter them, the Foundation assumes no responsibility or liability for their effective prevention or enforcement. Operational and Technical Risk: Exchanges operate interfaces that allow users to trade crypto-assets for fiat currencies, such as U.S. Dollars and Euros, or other crypto-assets. The reliance on the Exchange’s internal system for asset storage and transfer adds an additional layer of counterparty risk, as users are exposed to potential operational, technical, or human errors during these processes. As a result, the Foundation assumes no responsibility or liability for any losses arising from these risks. The following factors illustrate specific risks inherent to trading through Exchanges: Trades on Exchanges are usually executed based on a centralized matching algorithm and are often recorded off-chain, meaning they are not directly related to transparent on-chain transfers of crypto-assets, and could dissimulate detrimental trade matching or rogue practices. The traded assets are recorded solely on the Exchange’s internal ledger, with each internal ledger entry corresponding to an offsetting trade involving either government currency or another crypto-asset. Additionally, funds deposited by users for trading may be co-mingled by the Exchanges, rather than stored in unique wallet addresses for each user. This practice results in the centralization of a large volume of assets in a single location, which in turn increases the potential risk of damage or theft, particularly in the event of a hack or security breach. Furthermore, users who wish to trade or withdraw their Tokens may need to deposit them into the Exchange, increasing the risk of loss in the event of a failure of the deposit or withdrawal processes set up by the Exchange. Unanticipated Risks: In addition to the risks outlined in this Section, unforeseen risks may arise. Additionally, new risks could emerge as unexpected variations or combinations of the risks discussed in these Sections I.01 to I.05. |
| I.02 | Issuer - Related Risks | Abandonment / Lack of Success Risk: This is the risk that the activities around the Protocol must be partially or totally abandoned for several reasons including, but not limited to, lack of interest from the public, lack of funding, incapacitation of key developers and project members, force majeure (including pandemics and wars) or lack of commercial success or prospects. Project Change Risk: The project of the issuer may evolve over time. This could involve pivoting from its original vision, or modifying how that vision is executed. Such changes may be driven by market conditions, regulatory developments, technological advancements, or strategic decisions by the project’s team. While adaptation can foster innovation and resilience, it also introduces risks, including shifts in value proposition and potential misalignment with prior expectations. Withdrawing Partners Risk: The implementation of the Protocol depends strongly on the collaboration and functioning of services provided by several third parties and other crucial partners. Loss or changes in the project’s leadership or key partners can lead to disruptions, loss of trust, or project failure. The issuer or other legal entity of the ecosystem cannot guarantee that the Protocol and the related project will be successfully developed and deployed. Legal and Regulatory Compliance Risk: Crypto-assets and blockchain-based technologies are subject to evolving regulatory landscapes worldwide. Regulations vary across jurisdictions and may be subject to significant changes. This could lead to changes with respect to the trading of the Token and increase the issuer or other legal entity of the ecosystem’s costs and/or obligations in offering or admitting the Token for trading. Changes in laws or regulations may negatively impact the value, legality, or functionality of the Token. Non-compliance can result in investigations, enforcement actions, penalties, fines, sanctions, or the prohibition of the trading of the Token impacting its viability and market acceptance. The issuer or another legal entity of the ecosystem could also be subject to private litigation. Operational Risk: Any failure to develop or maintain effective internal control or any difficulties encountered in the implementation of such controls, or their improvement could harm the business of the issuer, causing disruptions, financial losses, or reputational damage. Inadequate management of technological updates or failure to keep pace with technological advancements can render a crypto-asset, or the project it is connected to, obsolete or vulnerable to security risks. Industry Risk: The issuer is and will be subject to all the risks and uncertainties associated with any new venture, visionary projects, including the risk that the issuer will not be able to realize its purpose or vision about the Protocol and the project. Other projects may have the same or a similar vision as the issuer. Many of such other projects are profit-oriented, substantially larger and have considerably greater financial, technical and marketing resources than the issuer does, and thus may attract more participants than the Protocol, the project and the ecosystem initiated by the issuer. Reputational Risk: The issuer faces the risk of negative publicity, whether due, without limitation, to operational failures, security breaches, or association with illicit activities, all of which can damage the issuer’s reputation and, by extension, the value and acceptance of the Token. Competition Risk: There are several other crypto-assets and projects, and new competitors may enter the market at any time. The effect of new or additional competition on the Token or its market price cannot be predicted or quantified. Competitors may have significantly greater financial and legal resources than the issuer and there is no guarantee that the issuer will be able to compete successfully, or at all, with such competitors. Moreover, increased competition may severely impact the profitability and creditworthiness of the issuer. Financial Risk: Issuers face financial risks, including liquidity, credit, and market risks. These could affect the issuer's ability to continue operations, meet obligations, or sustain the stability or value of the crypto-asset. Fraud and Mismanagement Risk: There is a risk of fraudulent activity or mismanagement by the issuer, which can lead to directly impacting the usability or value of a crypto-asset or damage the credibility of the project. Unanticipated Risks: In addition to the risks outlined in this Section, unforeseen risks may arise. Additionally, new risks could emerge as unexpected variations or combinations of the risks discussed in these Sections I.01 to I.05. |
| I.03 | Crypto-Assets-Related Risks | Market Risk: Crypto-assets, including the Token, are highly volatile and can experience significant price swings in short periods, increasing the risk of sudden and substantial losses. Such valuation risk arises as the market value of a crypto-asset may not always reflect its underlying utility or fundamentals and is subject to subjective assessment. Potential Token holders are thus exposed to potential for losses due to the Token’s: Potential fluctuations in value, driven by various factors such as supply and demand dynamics, investor sentiment, and broader market trends, incl. changes in interest rates, general movements in local and international markets technological advancements, regulatory changes, and media coverage. Notably, momentum pricing of crypto-assets has previously resulted, and may continue to result, in speculation regarding future appreciation or depreciation in the value of such assets, further contributing to volatility and potentially inflating prices at any given time. Liquidity risk, where a lack of depth in secondary markets – if any – or limited trading volumes can hinder the ability to execute trades at favorable prices, which could lead to significant losses, especially in fast-moving market conditions. As a result, holders of Tokens may experience challenges in managing their holdings, with the value of the asset subject to unpredictable fluctuations and potential depreciation. Solvency and collateral risk, if the Token is used to finance further activities, especially in leveraged positions or as collateral for loans. Significant fluctuations in the value of the Token could adversely affect the solvency of its holder particularly if the Token is pledged as collateral. A drastic decline in its value may trigger margin calls or automatic liquidations, which could further depress the Token's price, creating a negative feedback loop. This volatility poses the risk of forced asset sales, potentially resulting in substantial losses for the holder and amplifying downward pressure on the market price of Tokens. Custodial Risk: The method chosen to store Tokens, like any crypto-asset, carries inherent risks related to the security and management of the storage solution. The chosen storage method – whether hot or cold wallets, or centralized custody – can significantly impact the safety, liquidity, and accessibility of Tokens, with direct consequences for the holder's ability to access, trade, or retain their assets, including the risk of the custodian failing to fulfil their obligation due to insolvency, compliance issues or fraud, resulting in loss of Tokens. Scam Risk. This is the risk of loss resulting from a scam or fraud suffered by Token holders from other malicious actors. These scams include – but are not limited to – phishing on social networks or by email, fake giveaways, identity theft of the Foundation or its management body, creation of fake Tokens, offering fake Token airdrops, among others. Anti-Money Laundering/Counter-Terrorism Financing Risk: This is the risk that crypto-asset wallets holding Token or transactions in Token may be used for money laundering or terrorist financing purposes or identified to a person known to have committed such offenses. There is thus a risk that a public address holding Tokens could be flagged in relation to Anti-Money Laundering or Counter-Terrorism Financing efforts. In such cases, receiving Tokens could result in the holder’s address being flagged by relevant authorities, Exchanges, or other service providers, which may lead to restrictions on transactions or the freezing of assets. Consequently, holders of Tokens may face legal or regulatory challenges if their address becomes associated with illicit activities, impacting their ability to freely access, trade, or transfer their Tokens. Taxation Risk: The taxation regime that applies to the trading of Tokens by either individual holders or legal entities will depend on each potential Token holder’s jurisdiction. The Foundation cannot guarantee that the holding of Tokens, the reception of the Token, conversions of fiat currency against Tokens, or conversions of other crypto-assets against Tokens, will not incur tax consequences. It is the potential Token holder’s sole responsibility to comply with all applicable tax laws, including, but not limited to, the reporting and payment of income tax, wealth tax or similar taxes arising in connection with the appreciation and depreciation of the Token. Market Abuse Risk: The market for crypto-assets is rapidly evolving, spanning local, national, and international platforms with an expanding range of assets and participants. Any market abuse, along with a potential loss of confidence among holders, could adversely impact the value and stability of the Token. Notably: Significant trading activity may take place on systems and platforms with limited oversight and predictability. Sudden and rapid changes in the supply or demand of a crypto-asset, particularly those with low market capitalization or low unit prices, can result in extreme price volatility. Additionally, the inherent characteristics of crypto-assets and their underlying infrastructure may be exploited by certain market participants to engage in abusive trading practices such as front-running, spoofing, pump-and-dump schemes, and fraud across different platforms, systems, or jurisdictions. Legal and Regulatory Risk: There is a lack of regulatory harmonization and cohesion globally, which results in diverging regulatory frameworks and possible further regulatory evolutions in the future. These could negatively impact the value, utility, and overall viability of the Token and, in extreme cases, force the Foundation to cease operations. Notably: While the Token does not create or confer any contractual or other obligations against any party, certain non-EU regulators may nevertheless classify them as securities, financial instruments, or payment instruments under their respective legal frameworks. Such classifications could impose specific regulatory constraints, leading to significant changes in how the Token is structured, issued, purchased, or traded. Evolving regulations could substantially increase the Foundation’s compliance costs and operational burdens related to facilitating transactions in the Token. New or restrictive regulations could result in the Token losing functionality, depreciating in value, or even becoming illegal or impossible to use, buy, or sell in certain jurisdictions. Regulators could take enforcement action against the Foundation if they determine that the Token constitutes a regulated instrument or that the Foundation’s activities violate existing laws. Such actions could expose the Foundation, its affiliates, directors, and officers to legal and financial penalties, including civil and criminal liability. Unanticipated Risks: In addition to the risks outlined in this Section, unforeseen risks may arise. Additionally, new risks could emerge as unexpected variations or combinations of the risks discussed in these Sections I.01 to I.05 |
| I.04 | Project Implementation-Related Risks | Novel Ecosystem Risk: The potential Token holder understands and acknowledges that the ecosystem, as evolving around the Protocol, is built on emerging and rapidly evolving technologies, which inherently carry significant risks. The underlying software, blockchain infrastructure, smart contracts, and related technologies are still in their early stages of development, meaning there is no guarantee that the process of receiving, using, or holding Tokens will be uninterrupted or error-free. As with any novel technology stack, there is an inherent risk that the underlying blockchain, smart contracts, or associated components may contain weaknesses, vulnerabilities, or bugs, despite audits being conducted. Such issues could lead to unintended behaviors, security breaches, or critical failures, potentially resulting in the partial or complete loss of Tokens or their functionality. Additionally, unforeseen technical limitations, incompatibilities, or the emergence of superior alternatives could further impact the stability, security, and long-term viability of the ecosystem. Suitability Risk: The Protocol will be deployed on an "as is" and "as available" basis, with reasonable level of care but without warranties of any kind, and the Foundation expressly disclaims all implied warranties as to the Token, the Protocol including, without limitation, implied warranties of merchantability, fitness for a particular purpose, title and non-infringement. The Foundation does not warrant that the Token and/or, the Protocol are reliable, current or error-free, meet the Token’s requirements, or that defects in the Token and/or the Protocol will be corrected. The Foundation cannot and does not warrant that the Token, the software code of the Token smart contracts, or the delivery mechanism for Token or the Protocol, are free of viruses or other harmful components. Unanticipated Risks: In addition to the risks outlined in this Section, unforeseen risks may arise. Additionally, new risks could emerge as unexpected variations or combinations of the risks discussed in these Sections I.01 to I.05. |
| I.05 | Technology-Related Risks | The person seeking admission to trading, the issuer and its affiliate, directors and officers shall not be responsible or liable for any damages, losses, costs, fines, penalties or expenses of whatever nature, whether reasonably foreseeable by them and the potential Token holder, and which the potential Token holder, may suffer, sustain, or incur, arising out of or relating to the technical risks outlined below or a combination thereof. General Cybercrime Risk: The potential Token holder acknowledges that, despite best efforts to enhance security, the technological components supporting the Token – including its blockchain infrastructure, smart contracts, wallets – may be vulnerable to cyberattacks. Malicious actors may exploit software vulnerabilities, attack consensus mechanisms, or compromise private keys to gain unauthorized access to Tokens. Risks include hacking attempts on the Protocol, smart contract exploits, phishing attacks, malware infections, and other forms of cybercrime that could result in the theft, loss, or unauthorized transfer of Tokens. Since digital assets exist entirely in a technological environment, they are inherently exposed to evolving cyber threats, some of which may be undetectable or irreparable until after significant damage has occurred. Private Key Management Risk and Loss of Access to Crypto-Assets: The security of crypto-assets heavily relies on the management of private keys, which are used to access and control the crypto-assets (e.g. initiate transactions). If a Token holder loses access to their wallet (e.g. due to lost keys or seed phrase), they may irreversibly lose the ability to access their Tokens tied to that wallet. Settlement and Finality Risks: Due to the inherent characteristics of blockchain technology, transaction settlement is probabilistic rather than absolutely final. In exceptional circumstances, such as network forks, consensus failures, or other disruptions, transactions may be reversed, or multiple versions of the distributed ledger may coexist. Although the likelihood of such events decreases as additional blocks are added to the chain, it cannot be entirely eliminated. Once recorded and confirmed under normal network conditions, transactions are generally irreversible. Crypto-assets transferred to an incorrect or unintended address cannot be recovered, which may result in the permanent loss of those assets. Scaling Limitations and Transaction Fees: As the number of users and transactions grows, a blockchain network may face scaling challenges. This could lead to increased transaction fees and slower transaction processing times, affecting usability and costs Blockchain-Level Risk: The potential Token holder understands and accepts that, as with other blockchains, the blockchain used for the issuance of the Token could be susceptible to consensus-related attacks, including but not limited to double-spend attacks, DDoS attacks, majority validation power attacks, censorship attacks, and byzantine behavior in the consensus algorithm, Sybil attacks or be subject to forks. Any successful attack or fork presents a risk to the Token, the expected proper execution and sequencing of Token-transactions and the expected proper execution sequencing of contract computations as well as the token balances in the wallet of the potential Token holders. Smart Contract-Level Risk: The issuance and transfers of Tokens rely on smart contracts deployed on a blockchain network, which introduce specific technical and security risks, including the following: Smart contracts are self-executing, meaning any vulnerabilities, coding errors, or unforeseen logic flaws in the issuance contract could result in unintended consequences, such as the incorrect distribution of tokens, loss of funds, or permanent locking of tokens. Additionally, smart contracts are exposed to potential exploits, including hacking attempts, reentrancy attacks, and other forms of malicious activity that could compromise the security of the issuance process. Once deployed, the smart contract governing the issuance of Tokens cannot be easily altered or corrected, meaning any discovered vulnerabilities may be difficult or impossible to fix without significant coordination, community approval, or even a network fork. Furthermore, changes to the underlying blockchain protocol – such as updates to consensus mechanisms, transaction processing rules, or gas fee structures – could affect the functionality or cost efficiency of the issuance smart contract. These risks could lead to disruptions in token issuance, security breaches, or a loss of confidence in the ecosystem, potentially impacting the Token's value and usability. Protocol-Level Risk: It cannot be excluded that any technical failure, malfunction, attack, upgrade or vulnerability within the Protocol could directly or indirectly impact the value of the Token. The Protocol could be subject to critical exploits, such as reentrancy attacks, logic errors, or oracle manipulation, which could lead to unintended token transfers, assets being drained from the system, or Tokens being irretrievably lost. Fixing such issues may require significant coordination, governance approval, or even disruptive measures such as protocol migrations or forks, none of which are guaranteed to be successful. The Supply chain for the encryption technology used by the Protocol may be infiltrated by nefarious actors to gain privileged access to the Protocol. The Protocol could require an upgrade (for example, without limitation, to address a security concern), which could lead to a temporary halt of the Protocol or cause unforeseen disruptions to transactions on the Protocol. Third-Party Risk: Crypto-assets such as the Token often rely on third-party services such as exchanges and wallet providers for trading and storage. These providers can be susceptible to security breaches, operational failures, and regulatory non-compliance, which can lead to the loss or theft of crypto-assets. The Protocol encapsulate young technologies, which is why there is no warranty that the process for receiving, using, and holding the Token will be uninterrupted or error-free and that there is an inherent risk that the underlying blockchain, the smart contracts thereon, as well as any related technologies or concepts could contain weaknesses, vulnerabilities or bugs causing, inter alia, the complete loss of Token or its functionality. Anonymity and Privacy Risk: The inherent transparency and immutability of blockchain technology can pose risks to user anonymity and privacy. Since all transactions are recorded on a public ledger, there is potential for sensitive data to be exposed. The possibility for the public to link certain transactions to a specific address might expose it to phishing attacks, fraud, or other malicious activities. Unanticipated Risks: In addition to the risks outlined in this Section, unforeseen risks may arise. Additionally, new risks could emerge as unexpected variations or combinations of the risks discussed in these Sections I.01 to I.0 |
| I.06 | Mitigation Measures | While security tests are intended to be conducted before the token launch, potential Token holders understand that the risks outlined in Parts I.01 to 1.05 above are inherent to the Protocol activities and the broader ecosystem, and it is not possible to completely eliminate all risksmaking elimination impossible. |
| PART A – INFORMATION ABOUT THE offer or / THE PERSON SEEKING ADMISSION TO TRADING | ||
| A.01 | Name | Liquid Bitcoin Foundation |
| A.02 | Legal Form | Exempted Foundation Company Limited By GuaranteeExempted Limited Guarantee Foundation Incorporated |
| A.03 | Registered Address | Compass OFM Limited, 3rd Floor Suite 5304, 18 Forum Lane, Camana Bay, P.O. Box 31230, Grand Cayman KY1-1205, Cayman Islands |
| A.04 | Head Office | Not applicable. |
| A.05 | Registration Date | April 25, 2025 |
| A.06 | Legal Entity Identifier | Not applicable. |
| A.07 | Another Identifier Required Pursuant to Applicable National Law | Registration Number in the Cayman Islands Commercial Register: CR-420906 |
| A.08 | Contact Telephone Number | +1 345 324-3516 |
| A.09 | E-Mail Address | operations@liquidbitcoin.foundation |
| A.10 | Response Time (Days) | Inquiries are usually answered within 7 days. For specific or more complex requests - as determined and communicated by the Foundation - processing may take up to 10 days. |
| A.11 | Parent Company | Not applicable. |
| A.12 | Members of the Management Body | The Management Body is composed of: Name Business Address Function Marc Philip Alessandro Piano Compass OFM Limited, 3rd Floor Suite 5304, 18 Forum Lane, Camana Bay, P.O. Box 31230, Grand Cayman KY1-1205, Cayman Islands Director Medas Girdzius Compass OFM Limited, 3rd Floor Suite 5304, 18 Forum Lane, Camana Bay, P.O. Box 31230, Grand Cayman KY1-1205, Cayman Islands Director Toghrul Maharramov Compass OFM Limited, 3rd Floor Suite 5304, 18 Forum Lane, Camana Bay, P.O. Box 31230, Grand Cayman KY1-1205, Cayman Islands Director |
| A.13 | Business Activity | The Foundation oversees Protocol’s governance, its respective ecosystem development, and research for the Protocol. Its principal activities include appointing key personnel, guiding technical upgrades, funding grants, supporting public goods, and facilitating partnerships for the Protocol. |
| A.14 | Parent Company Business Activity | Not applicable. |
| A.15 | Newly Established | True. |
| A.16 | Financial Condition for the Past Three Years | Not applicable. |
| A.17 | Financial Condition since Registration | The Foundation was recently established under the laws of the Cayman Islands and is not required to produce financial statements under Cayman law. The Foundation and the operation of the Protocol is funded by capital raised from venture capital and other investors (i.e. $16 million raised in 2024). The Foundation also controls 20% of BARD token total supply. The Foundation has no outstanding liabilities, debts, or financial commitments. To support operations and future initiatives, the Foundation plans to secure additional funding through a public sale of the Token. |
| PART B - INFORMATION ABOUT THE ISSUER, IF DIFFERENT FROM THE offer or OR PERSON SEEKING ADMISSION TO TRADING | ||
| B.01 | Issuer Different from the Person Seeking Admission to Trading | True |
| B.02 | Name | Liquid Bitcoin Operations Inc. |
| B.03 | Legal Form | Corporation |
| B.04 | Registered Address | Province of Panama, district of Panama, Betania, Vía Ricardo J. Alfaro, PH The Century Tower, office three hundred seventeen (317). |
| B.05 | Head Office | Not applicable. |
| B.06 | Registration Date | May 20, 2025 |
| B.07 | Legal Entity Identifier | Not applicable. |
| B.08 | Another Identifier Required Pursuant to Applicable National Law | Registration Number in the Panamanian Commercial Register: 155767515 |
| B.09 | Parent Company | Liquid Bitcoin Foundation |
| B.10 | Members of the Management Body | The Management Body is composed of: Name Business Address Function Natasha Carolina Diaz Proll Compass OFM Limited, 3rd Floor Suite 5304, 18 Forum Lane, Camana Bay, P.O. Box 31230, Grand Cayman KY1-1205, Cayman Islands Director Pedro Luis Zapata Vega Compass OFM Limited, 3rd Floor Suite 5304, 18 Forum Lane, Camana Bay, P.O. Box 31230, Grand Cayman KY1-1205, Cayman Islands Director Lorena Del Carmen Diaz Moreira Compass OFM Limited, 3rd Floor Suite 5304, 18 Forum Lane, Camana Bay, P.O. Box 31230, Grand Cayman KY1-1205, Cayman Islands Director |
| B.11 | Business Activity | The issuer operates the Protocol, including protocol execution, vault management, token issuance, custodial LBTC minting, and the front-end interface. Its principal market is Bitcoin-based capital markets. |
| B.12 | Parent Company Business Activity | See A.13 above. |
| PART C- INFORMATION ABOUT THE OPERATOR OF THE TRADING PLATFORM IN CASES WHERE IT DRAWS UP THE CRYPTO-ASSET WHITE PAPER AND INFORMATION ABOUT OTHER PERSONS DRAWING THE CRYPTO-ASSET WHITE PAPER PURSUANT TO ARTICLE 6(1), SECOND SUBPARAGRAPH, OF REGULATION (EU) 2023/1114 | ||
| C.01 | Name | Not applicable. |
| C.02 | Legal Form | Not applicable. |
| C.03 | Registered Address | Not applicable. |
| C.04 | Head Office | Not applicable. |
| C.05 | Registration Date | Not applicable. |
| C.06 | Legal Entity Identifier of the Operator of the Trading Platform | Not applicable. |
| C.07 | Another Identifier Required Pursuant to Applicable National Law | Not applicable. |
| C.08 | Parent Foundation | Not applicable. |
| C.09 | Reason for Crypto-Asset White Paper Preparation | Not applicable. |
| C.10 | Members of the Management Body | Not applicable. |
| C.11 | Operator Business Activity | Not applicable. |
| C.12 | Parent Foundation Business Activity | Not applicable. |
| C.13 | Other Persons Drawing up the Crypto- Asset White Paper According to Article 6(1), Second Subparagraph, of Regulation (EU) 2023/1114 | Not applicable. |
| C.14 | Reason for Drawing the White Paper by Persons Referred to in Article 6(1), Second Subparagraph, of Regulation (EU) 2023/1114 | Not applicable. |
| PART D – INFORMATION ABOUT THE CRYPTO-ASSET PROJECT | ||
| D.01 | Crypto-asset Project Name | Lombard Finance |
| D.02 | Crypto-Assets Name | BARD Token |
| D.03 | Abbreviation | BARD |
| D.04 | Crypto-Asset Project Description | The Crypto-Asset Project - The Protocol is a technical infrastructure enabling BTC holders to access a broad spectrum of BTC-focused DeFi products and services. The Protocol Components - The Protocol has three main components: Babylon Protocol: The Protocol is built on top of the Babylon Protocol, an independent staking protocol that uses native BTC to secure proof-of-stake (“PoS”) networks. Lombard Ledger (Security Consortium): A Bitcoin Security mechanism operated by independent institutions that ensure the security of the Protocol by validating every transaction on the Protocol. LBTC (tokenized Bitcoin through smart contracts): BTC holders that stake their BTC through the Protocol in order to participate in the securing of PoS networks receive in exchange a receipt token (“LBTC”), denoting the amount of delegated BTC, minted as a token on various blockchains. The Crypto-Asset - The Token is the Network Token, for more details see (D.07). |
| D.05 | Details of all Natural or Legal Persons Involved in the Implementation of the Crypto-Asset Project | Full Name Business Address Function Cubist, Inc. 1755 Friedrick Dr San Diego, CA 92104, USA Infrastructure/Security Zeppelin Group Limited 5 New Street Square London, United Kingdom EC4A 3TW Security TRM Labs, Inc. 450 Townsend Street, San Francisco, CA 94107, United States Security Sherlock Co. Dresdner Tower, 11th Floor 50th St. and 55th East Street Panama City, Panama 00000 Security Veridise Inc. 7109 Midwood Pkwy Austin, TX 78736 Security Halborn Inc. 114 NW 25th St, #143 Miami, FL 33127 US Security ABDK Audits OU Narva mnt 5, 10117, Tallinn, Estonia Security Distributed Data Labs Sp. z o.o. Al. Jerozolimskiego 96 00-807 Warsaw Mazowieckie Poland Infrastructure Chainlink Labs Inc. 251 Little Falls Drive, Wilmington, New Castle County, DE 19808 Infrastructure Informal Systems Inc. 180 John St Tornonto ON M5T1X5, Canada Infrastructure Hexagate Ltd. 13 Yehuda and Noah Moses, Israel Security MME Legal Ltd. Zollstrasse 62 P.O. Box |
| D.06 | Utility Token Classification | True. |
| D.07 | Key Features of Goods/Services for Utility Token Projects | By holding the Token, Token holders can: Participate in the Protocol Governance: The purpose of the governance functionality of the Token is to create a stable and trustworthy ecosystem by allowing Token holders to access and participate in the decentralized, balanced ecosystem consensus mechanism. Protocol Governance: Token holders can adjust certain parameters of the Protocol and vote on Protocol upgrades; and Protocol Security: Token holders can vote on the composition of the Security Consortium (as defined in D.04). Token holders only participate in technical and/or operational decision-making but have no influence over the corporate governance of the offer or / person seeking admission to trading, or any other party of the Protocol ecosystem. |
| D.08 | Plans for the token | Token Generation Event (“TGE”): Not yet occurred as of the date of the notification but is expected for second half of 2025. First Token Sale: The Token will be offered for sale on or around 28 August 2025 (the “Starting Date”). While this initial sale within the EU/EEA qualifies as an offer under MiCA, it will not exceed EUR 1,000,000 over a 12-month period from the Starting Date. This initial sale is therefore not the subject of the present white paper and does not require the publication or notification of a white paper pursuant to Article 4(2)(b) of MiCA. Listing within the EU/EEA on Trading Platforms: See F:09 (not defined yet) |
| D.09 | Resource Allocation | The financial resources allocated to the project are further explained in A.17 above. |
| D.10 | Planned Use of Collected Funds or Crypto-Assets | The raised funds through the First Sale shall be used for the further development of the Protocol and the respective ecosystem. |
| PART E – INFORMATION ABOUT THE OFFER TO THE PUBLIC OF CRYPTO-ASSETS OR THEIR ADMISSION TO TRADING | ||
| E.01 | Admission to Trading | Admission to Trading (ATTR) |
| E.02 | Reasons for the Admission to Trading | To promote broad circulation and distribution among potential Protocol participants, enabling them to fully engage with and benefit from the Protocol. Furthermore, listing the Token on secondary markets is expected to enhance its liquidity. |
| E.03 | Fundraising Target | Not applicable. No funds are raised. The present white paper is solely drafted for the purpose of the admission of the Token to trading within the EU/EEA. |
| E.04 | Minimum Subscription Goals | Not applicable. See E.03. |
| E.05 | Maximum Subscription Goal | Not applicable. See E.03. |
| E.06 | Oversubscription Acceptance | Not applicable. See E.03. |
| E.07 | Oversubscription Allocation | Not applicable. See E.03. |
| E.08 | Issue Price | Not applicable. See E.03. |
| E.09 | Official Currency or any Other Crypto-Assets Determining the Issue Price | Not applicable. See E.03. |
| E.10 | Subscription Fee | Not applicable. See E.03. |
| E.11 | Offer Price Determination Method | Not applicable. See E.03. |
| E.12 | Total Number of Offered / Traded Crypto-Asset | Up to the Token total supply. |
| E.13 | Targeted Holders | ALL, meaning both Retail (RETL) and Professional (PROF). |
| E.14 | Holder restrictions | Trading Platforms, in accordance with applicable laws and their internal policies, may impose restrictions on Token buyers and sellers. These may include, among others, the successful completion of Know Your Customer (KYC) procedures, Anti-Money Laundering (AML) checks, and measures to combat the financing of terrorism (CFT). |
| E.15 | Reimbursement Notice | Not applicable. See E.03. |
| E.16 | Refund Mechanism | Not applicable. See E.03. |
| E.17 | Refund Timeline | Not applicable. See E.03. |
| E.18 | Offer Phases | Not applicable. See E.03. |
| E.19 | Early Purchase Discount | Not applicable. |
| E.20 | Time-Limited Offer | Not applicable. See E.03. |
| E.21 | Subscription Period Beginning | Not applicable. See E.03. |
| E.22 | Subscription Period End | Not applicable. See E.03. |
| E.23 | Safeguarding Arrangements for Offered Funds/Crypto-Assets | Not applicable. See E.03. |
| E.24 | Payment Methods for Crypto-Asset Purchase | Not applicable. See E.03. |
| E.25 | Value Transfer Methods for Reimbursement | Not applicable. See E.03. |
| E.26 | Right of Withdrawal | Not applicable. See E.03. |
| E.27 | Transfer of Purchased Crypto-Assets | The purchased Tokens shall be transferred to the purchaser’s compatible wallet or technical device as designated by the Trading Platforms. The Foundation bears no responsibility for any transfers of the Token between buyers and sellers conducted on the Trading Platforms. |
| E.28 | Transfer Time Schedule | The transfer of the Tokens on the Trading Platforms from the seller’s wallet or device to the buyer’s wallet or device may not occur immediately. The Foundation has no control over the timing of such transfers. |
| E.29 | Purchaser's Technical Requirements | Potential Token holder must comply with the technical requirements specific to the Trading Platforms on which the Token is admitted to trading, which may include, among others, (i) an internet access (ii) a compatible digital wallet or account on supported Trading Platform and (iii) a device (computer or mobile) to manage digital wallet/private key and/or account on exchange to carry out transactions. |
| E.30 | Crypto-Asset Service Provider (CASP) Name | Not applicable. |
| E.31 | CASP Identifier | Not applicable. |
| E.32 | Placement Form | Not applicable. |
| E.33 | Trading Platforms Name | Admission to trading is being sought on Trading Platforms operating within the EU/EEA. As of the date of notification of the present white paper, no listing agreement has been concluded; therefore, no specific platform can be identified at this stage. |
| E.34 | Trading Platforms Market Identifier Code (MIC) | Not applicable. |
| E.35 | Trading Platforms Access | Trading Platforms are accessible via their respective website or applications for mobile device. |
| E.36 | Involved Costs | The use of services offered by Trading Platforms may involve costs, including transaction fees, withdrawal fees, and other charges, as notified to users in advance. These costs are determined and set by the respective Trading Platforms and are not controlled, influenced, or governed by the Foundation. Consequently, any changes to initially announced fee structures or the introduction of new costs for the future are solely at the discretion of the Trading Platforms. |
| E.37 | Offer Expenses | Not applicable. |
| E:38 | Conflicts of Interest | Not applicable. |
| E.39 | Applicable Law | Any dispute arising out of or in connection with the present white paper, the Foundation and the admission to trading shall be governed exclusively by the laws of Cayman Islands, without regard to conflict of law rules or principles, except to the extent that such disputes are governed by applicable law pursuant to the terms and conditions of the respective Trading Platform on which the Token has been admitted for trading. |
| E.40 | Competent Court | Any dispute arising out of or in connection with the present white paper, the Foundation and the admission to trading shall be exclusively resolved by the ordinary courts of Cayman Islands. |
| PART F – INFORMATION ABOUT THE CRYPTO-ASSET | ||
| F.01 | Crypto-Asset Type | Crypto-asset other than asset-referenced tokens and e-money tokens and more specifically a utility token. |
| F.02 | Crypto-Asset Functionalities | By holding the Token, Token holders can: Participate in the Protocol Governance: The purpose of the governance functionality of the Token is to create a stable and trustworthy ecosystem by allowing Token holders to access and participate in the decentralized, balanced ecosystem consensus mechanism. Protocol Governance: Token holders can adjust certain parameters of the Protocol and vote on Protocol upgrades; and Protocol Security: Token holders can vote on the composition of the Security Consortium (as defined in D.04). Token holders only participate in technical and/or operational decision-making but have no influence over the corporate governance of the offer or / person seeking admission to trading, or any other party of the Protocol ecosystem. |
| F.03 | Planned Application of Functionalities | The Token will be issued fully functional, i.e., with all functionalities described in F.02. While further applications may be introduced in the future, there is no commitment, promise or guarantee that such functionalities will be implemented. |
| A description of the characteristics of the crypto-asset, including the data necessary for classification of the crypto-asset White Paper in the register referred to in Article 109 of Regulation (EU) 2023/1114, as specified in accordance with paragraph 8 of that Article | ||
| F.04 | Type of White Paper | OTHR |
| F.05 | The Type of Submission | New (NEWT) |
| F.06 | Crypto-Asset Characteristics | The Token is a crypto asset other than asset-referenced tokens or e-money tokens of the Protocol and more specifically a utility token. |
| F.07 | Commercial Name or Trading Name | BARD Token |
| F.08 | Website of the Issuer | https://www.lombard.finance/ |
| F.09 | Starting Date of the Offer and the Admission to Trading | The starting date has not yet been determined and will be agreed upon in coordination with the Trading Platform. In any case, the trading of the Token shall not start before the white paper is published (See F.10). |
| F.10 | Publication Date | September 13, 2025 (intended publication date) |
| F.11 | Any other Services Provided by the Issuer | Not applicable. |
| F.12 | Identifier of Operator of the Trading Platform | Not applicable. |
| F.13 | Language or Languages of the White Paper | English. |
| F.14 | Digital Token Identifier Code used to uniquely Identify the Crypto-Asset or each of the Several Crypto Assets to which the White Paper relates, where Available | Not applicable. |
| F.15 | Functionally Fungible Group Digital Token Identifier, where Available | Not applicable. |
| F.16 | Voluntary Data Flag | False. |
| F.17 | Personal Data Flag | True. |
| F.18 | LEI Eligibility | Not applicable. The Foundation is not required to provide an LEI under MiCA. |
| F.19 | Home Member State | Ireland pursuant to Article 3 (33) (c) of Regulation. |
| F.20 | Host Member States | The admission to trading of the Token is passported in the following countries: Austria, Belgium, Bulgaria, Croatia, Cyprus, Czechia, Denmark, Estonia, Finland, France, Germany, Greece, Hungary, Iceland, Italy, Latvia, Liechtenstein, Lithuania, Luxembourg, Malta, Netherlands, Norway, Poland, Portugal, Romania, Sweden, Slovakia, Slovenia, Spain |
| PART G – INFORMATION ON RIGHTS AND OBLIGATIONS ATTACHED TO THE CRYPTO-ASSETS | ||
| G.01 | Purchaser Rights and Obligations | The Token does not entail any purchaser rights or obligations. The Token enables the potential Token holder to participate in the governance of the Protocol. |
| G.02 | Exercise of Rights and Obligations | Not applicable. |
| G.03 | Conditions for Modifications of Rights and Obligations | Not applicable. |
| G.04 | Future Public Offers | Not applicable. |
| G.05 | Issuer Retained Crypto-Assets | No current plan. However, the Foundation will be allocated 20% of the total token supply. |
| G.06 | Utility Token Classification | True. |
| G.07 | Key Features of Goods/Services of Utility Tokens | By holding the Token, Token holders can: Participate in the Protocol Governance: The purpose of the governance functionality of the Token is to create a stable and trustworthy ecosystem by allowing Token holders to access and participate in the decentralized, balanced ecosystem consensus mechanism. Protocol Governance: Token holders can adjust certain parameters of the Protocol and vote on Protocol upgrades; and Protocol Security: Token holders can vote on the composition of the Security Consortium (as defined in D.04). Token holders only participate in technical and/or operational decision-making but have no influence over the corporate governance of the offer or / person seeking admission to trading, or any other party of the Protocol ecosystem. |
| G.08 | Utility Tokens Redemption | Not applicable. |
| G.09 | Non-Trading Request | True. |
| G.10 | Crypto-Assets Purchase or Sale Modalities | Not applicable. |
| G.11 | Crypto-Assets Transfer Restrictions | Not applicable. |
| G.12 | Supply Adjustment Protocols | False. |
| G.13 | Supply Adjustment Mechanisms | Not applicable. |
| G.14 | Token Value Protection Schemes | False. |
| G.15 | Token Value Protection Schemes Description | Not applicable. |
| G.16 | Compensation Schemes | False. |
| G.18 | Applicable Law | Any dispute arising out of or in connection with the present white paper, the Foundation, the Token and/or the Protocol shall be governed exclusively by the laws of the Cayman Islands, without regard to conflict of law rules or principles, except to the extent that such disputes are governed by applicable law pursuant to the terms and conditions of the respective Trading Platform on which the Token has been admitted for trading. |
| G.19 | Competent Court | Any dispute relating to the present white paper, the Foundation, the Token and/or the Protocol shall be exclusively resolved by the ordinary courts of Cayman Islands. |
| PART H – INFORMATION ON THE UNDERLYING TECHNOLOGY | ||
| H.01 | Distributed ledger technology | Pursuant to article 3 (1) and (2) of MiCA, a Distributed Ledger technology means a technology that enables the operation and use of distributed ledgers, i.e., an information repository that keeps records of transactions and that is shared across, and synchronized between, a set of DLT network nodes using a consensus mechanism. The Protocol leverages the Cosmos SDK technology, a mature DLT stack that underpins many protocolsstandard [information]. |
| H.02 | Protocols and technical standards | Common Token Standards: ERC-20 for Ethereum Virtual Machine blockchains and Solana Program Library (SPL) for the Solana blockchain. This ensures compatibility with wallets, decentralised exchanges (DEX) and composability with decentralised applications. Staking Security: Cubist’s CubeSigner is a market leading Trusted Execution Environment for self-custodial key management with low-latency execution where transaction signing is optimised compared tovia alternative cryptographic technologies (such as Multi-Party Computation). Double Verification: All transactions on the protocol are notarised by both the Security Consortium and a third-party oracle check, either by Cubist’s CubeSigner or Chainlink. Efficiency and Security Trade-Offs: Transactions are optimised for security first and efficiency second, given industry standard definitions of finality on various blockchains that the Protocol supports. |
| H.03 | Technology Used | See field H.02. |
| H.04 | Consensus Mechanism | The Protocol utilizes a Proof-of-Authority mechanism with a 75% threshold. Each validator is a member of Lombard’s Security Consortium - some of the most trusted institutions within crypto, to ensure social consensus. Each member is also privately incentivized to cover operational costs on an annual basis. |
| H.05 | Incentive Mechanisms and Applicable Fees | See field H.03. |
| H.06 | Use of Distributed Ledger Technology | False. |
| H.07 | DLT Functionality Description | Not applicable. |
| H.08 | Audit | True. |
| H.09 | Audit outcome | The Protocol has a comprehensive audit program and has successfully completed multiple audits on its public smart contracts (link) by providers including OpenZeppelin, Veridise, and Halborn. |
| PART J – INFORMATION ON THE SUSTAINABILITY INDICATORS IN RELATION TO ADVERSE IMPACT ON THE CLIMATE AND OTHER ENVIRONMENT-RELATED ADVERSE IMPACTS | ||
| J.01 | Adverse impacts on climate and other environment-related adverse impacts | The Foundation is providing information on principal adverse impacts on the climate and other environment-related adverse impacts of the consensus mechanism used to validate transactions of the Token and to maintain the integrity of the distributed ledger of transactions. The energy consumption for the validation of transactions and the maintenance of the integrity of the distributed ledger of transactions for the period is estimated to be lower than 500’000 kWh. The figure provided in S.08 is intended to reference annualized amounts. |
| S.02 | Name | Liquid Bitcoin Foundation. |
| S.03 | Relevant legal entity identifier | Not applicable. |
| S.04 | Name of the crypto-asset | BARD Token |
| S.05 | Consensus Mechanism | See H.04 |
| S.06 | Incentive Mechanisms and Applicable Fees | See H.05 |
| S.07 | Beginning of the period to which the disclosure relates | July 2025 |
| S.08 | End of the period to which the disclosure relates | July 2026 |
| S.09 | Energy consumption | < 500’000 kWh The total estimated energy consumption for the Network from July 2025 to July 2026 is approximately 435 kWh per year. |
| S.10 | Energy consumption sources and methodologies | The estimated energy consumption provided in J.08 has been calculated using the methodology, recommended by: CCRI-Whitepaper-MiCA-Methods-2024.pdf. |