White Swan ($SWAN) is the first memecoin – and token – issued under the EU’s Markets in Crypto-Assets (MiCA) regulation Title II.

$SWAN raised 1694 SOL – valued at approximately €300,000 – during its ICO in January 2025. It was determined that the funds raised should be primarily held in SOL to provide $SWAN holders indirect beta to SOL.

The Finnish Tax Administration (FTA) determined the ICO proceeds to be subject to the general Value Added Tax (VAT) rate of 25.5%. The $SWAN governing entity disputed this decision throughout 2025/6.

However, even after escalation to the Helsinki Administrative Court, the ruling was determined to stand. Simultaneously, during this period from the ICO to Oct 20, 2026, the price of SOL fell by as much as ~70%, at its low valuing the ICO proceeds at roughly 89,000€ before any costs incurred by the governing entity.

$SWAN realised the beta of SOL on its operational expenditures through SOL’s downward price trend and the VAT decision upheld in favour of the FTA. On Oct 20, 2026, the governing entity’s board resolved to be unable to pay the VAT charges and filed for bankruptcy, even after an additional external capital injection of ~€12,000.

At the time of publication, Oct 27, 2026, the estate of the governing entity holds approximately 365m $SWAN. The governing entity has appointed Attorneys-at-Law Muukkonen & Mäkelä Oy as its representatives in the bankruptcy proceedings. It is expected that all remaining assets of the governing entity – including the $SWAN tokens & any LP positions – are to be handed over to the FTA as the entity’s primary creditor.

Following the initiation of the bankruptcy proceedings, the RegTech company Pristine Compliance Solutions Oy has pledged to maintain and update the MiCA white papers and compliance of the $SWAN token at least until 2030.

All brand, technical IP, and other assets produced to support the flight of $SWAN have been fully open-sourced and are available through the $SWAN FOSS Browser.

Sincerely,
$SWAN Team