Greenfield Complains to Swiss ESA About Safe Foundation
Safe early investor Greenfield Capital has issued an open letter stating that it has submitted a regulatory complaint regarding the Safe Ecosystem Foundation to the Swiss Federal Foundation Supervisory Authority this week, with the document type being Aufsichtsanzeige.
Greenfield invested in Safe during its financing round after the 2022 spin-off from Gnosis and has not sold any SAFE tokens to date. The open letter claims that Safe's account assets have dropped from approximately $66 billion in January 2024 to about $30 billion in August 2026, a decline of over 50%; during the same period, the total locked value in DeFi has increased by about 40%, with Safe's relative share shrinking to about one-third. The total supply of stablecoins has increased from about $130 billion to over $300 billion, a growth of approximately 135%, while the stablecoins within Safe on the Ethereum mainnet have only increased from $5.9 billion to $6.6 billion, an increase of about 11%; the share of circulating USDC held by Safe has dropped from 12.8% to 2.5%.
The foundation raised approximately $93.5 million in 2022. A disclosure in May 2026 by MiCA indicated that about $60 million of this had been spent, leaving approximately $34 million in cash; the foundation also holds a strategic reserve of 8.5% of the total supply and 45% of SAFE on its balance sheet. During the same period, the price of SAFE has dropped by over 95%. By the end of 2025, the foundation reported an annualized income of over $10 million, approximately $2 million by the end of 2024; in the second quarter of 2026, income was $1.98 million, annualized at about $8 million, below the implied breakeven target of about $20 million for 2026, with a target of $100 million in annualized income by 2030.
About a year ago, Greenfield stated that it could not assess the situation based solely on team information, so it collaborated with former employees, key users, ecosystem developers, and other investors for an independent review, submitting an investor memorandum in December 2025. The review concluded that the board at that time had only two members with no independent voices, with Gnosis co-founder Stefan George serving as a director, while Gnosis had previously operated a wallet that directly competed with Safe{Wallet}. After the Bybit hack in February 2025, the letter stated that Stefan George and Gnosis co-founder Martin Köppelmann demanded that other directors and co-founders hand over a large amount of SAFE, or Gnosis would sell about 10% of its holdings and publicly cut ties; the other party conceded and completed the redistribution. The bylaws require at least three directors, but from September 2025 to April 2026, there were only two, and the vacancy was filled by Richard Meissner.
Since the end of 2025, Greenfield has directly and through lawyers made three demands: to update the board and introduce independent members, to adjust the management team, and for the board to review strategy, products, organization, and token economics, setting quantifiable metrics. It has explicitly stated that it does not seek a board seat for itself. In June 2026, the foundation established a non-decision-making strategic committee, while the board remained the original three members. Greenfield stated that this action is not a lawsuit against individuals and does not intend to take over Safe, maintaining a positive attitude towards Safe Labs and continuing to participate as an ecosystem participant and Safenet validator; its validator delegation size is second only to Gnosis.
The complainants are early shareholders who have not reduced their holdings, and the pressure is directed at the Swiss foundation's board, not secondary market sell-offs. The driving force behind the event comes from the decline in asset shares and the composition of the board. Funds remain locked in unsold SAFE and the foundation's treasury. Beneficiaries are the token holders pushing for independent directors, while the pressured parties are the existing directors named and those who have delegated custody needs to Coinbase and BitGo.
Coinbase's institutional custody assets have increased from about $100 billion at the end of 2023 to about $250 billion by mid-2025, while BitGo's assets have grown from about $60 billion to over $90 billion before its IPO in January 2026. Safe has not disclosed the specific number of shares held by Greenfield.
Source: Public Information
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Greenfield's entry point was the 2022 spin-off of Safe from Gnosis. The board later consisted of former Gnosis employees Lukas Schor, Christoph Simmchen, and Gnosis co-founder Stefan George, with Christoph Simmchen leaving after the Bybit incident. Gnosis is both a holder of about 10% of SAFE and has operated a wallet that competes with Safe{Wallet}, and it ranks ahead of Greenfield in Safenet validator delegation. The spin-off did not sever the personnel and token leverage from the parent company.
The open letter framed the redistribution after the Bybit hack in February 2025 as a governance action: threatening to sell about 10% of the supply in exchange for other founders handing over SAFE. Greenfield's chosen path was not to sell itself, but to submit a memorandum in December 2025, followed by a lawyer's letter, and then the regulatory complaint to the Swiss foundation in October 2026. The foundation responded with a non-voting strategic committee, effectively leaving external participation at the advisory level. Of the $93.5 million raised, about $60 million has been spent, with annualized income still around $8 million.
A comparable situation is the lawsuit between the Tezos foundation and early investors after 2017, as well as Uniswap's decision to keep treasury decision-making power with the foundation rather than token voting after 2020. The stage Safe is in is not product expansion, but control confirmation: the protocol still manages about $30 billion in assets, with decision-making power resting with three directors. Custody needs have concurrently flowed to Coinbase and BitGo, while self-custody shares have not followed the stablecoin supply.
Essentially, this is a reclamation of governance rights amid regulatory changes. Swiss foundation law requires a minimum number of directors and conflict of interest avoidance, and investors are using the ESA complaint to turn internal vacancies into external scrutiny. The mechanism is that after a 95% drop in token value, the secondary market has already priced in failure, and unsold shareholders can only change the board, not alter treasury expenditures through selling. The non-decision-making committee does not change signing authority, and the complaint targets this gap.
ABAB News · Cognitive Laws
The spin-off severs equity but does not sever personnel.
The advisory committee has seats but no signing authority.
When shares are falling, those who do not sell can only change the board.