A note on Regenesis Labs Funds Management

DCL Regenesis Labs
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Thanks to @SinfulMeatStick and @toxicwaifu for hosting last Monday Beyond the NFT session with the DAO Council candidates. I didn’t join live; it was 2:00 AM where I am, but I watched the recording yesterday. While listening, I heard some questions and concerns that were better directed to current Council members or to me, as the Regenesis Labs Executive Director, rather than to the candidates. Combined with messages that current DAO Committee member @rizk posted on the DAO Discord, this made me want to write this note for clarity.

These are some of the concerns I heard. Please let me know in the comments below if I should address anything else.

Concern 1 — Transfers from the Regenesis Labs Treasury to the Regenesis Labs Operational Wallet

Why it happened: Regenesis Labs is an operating organization. Starting in September, we will have ~10 full/part-time contributors, we also have two project-based contributors, vendors, equipment, and monthly bills. Pulling funds from a co-managed treasury multisig for every invoice is inefficient and increases operational risk. Council members are usually available, but it’s not their job to be on call to sign transactions whenever I request it. That’s why, after the funding transfer from the DAO Treasury, a portion of the funds was transferred to the Operational Wallet. It’s worth mentioning that this happened in June. I’m not sure why this is being raised now as a concern, but I’m happy to clarify.

The Operational Wallet has existed since the original 18-month operating budget proposal (see the operational diagram I presented at the Town Hall where I walked through the operating budget).

The first treasury → operational transfer occurred in June, when we began operations. Two transfers were made: one in stablecoins to cover the first month of operations (before the large MANA transfer by the DAO Committee), and a second one in MANA.

The transfer was requested by me with Council approval and was signed by two Council members and me.

Regenesis Labs is solely responsible for the operational funds, and we can decide what we do to maximize them. Having a portion of the funds under our control allowed us to buy MANA at the best price possible over the last three months and deposit funds in low-risk stablecoin yield generation protocols. We will continue to do this because every MANA we exchange over our break-even price of 0.26 and every % of yield we generate from our budget is less MANA we will have to use from our budget.

Everything we did has been on-chain and has been reflected in our monthly updates. If you missed it, we’ll work to make it easier to see.

Concern 2 — Lack of transparency in spending

We’re executing what we committed to:

All vendor payments are invoiced and are paid on-chain via Request.finance, and are visible from the multisig in real time.

We’ll publish quarterly reports with a project narrative and spend breakdown (monthly financial reporting would require a dedicated reporting team we don’t have, and we don’t think that’s a priority right now). The first one is due in October, covering June–September (we aligned quarters to the calendar year from the start).

We’ve been publishing timely monthly updates at the beginning of each month. See June and July.

As we said when we proposed this structure, transparency should be built into how we operate. We are sharing an in-progress public dashboard now (originally planned for quarter-end) to centralize what matters—initiatives, progress, and spend.

Dashboard link

Screenshot 2025-08-27 at 4.24.08 PM
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If something is unclear, please comment with suggestions, and we’ll iterate.

Concern 3 — “One person has unilateral access to DAO funds”

Regenesis has operational autonomy only over the funds allocated to Regenesis (not the DAO treasury). The DAO Council provides oversight—think board-level accountability for spending and results against the approved plan, rather than day-to-day approvals.

A comment was made about me holding two keys of the Operational Wallet. Point taken. If something happens to me, the funds on that multisig would be locked. We have added a temporary trusted recovery key from a Regenesis Labs team member. I’ll ask the Council if a member is willing to serve as a recovery mechanism; if not, through this post, I’m inviting a DAO Committee member who is willing to complete KYC to fill that role.

Legal accountability: Regenesis operates under a Cayman Islands Foundation structure. I am personally accountable for the lawful use of Regenesis funds. As opposed to the DAO Treasury, which is not protected by any legal wrapper, the Regenesis Labs Treasury is. The Foundation bylaws are explicit about me not having any protection if I perform “actual fraud, wilful default, or Gross Negligence.” In addition, I must act in good faith in the Foundation’s best interests. Also, it prohibits distributing the Foundation’s income or property to members other than authorised remuneration for services.

Concern 4 — Double Spending between Decentraland Foundation and DCL Regenesis Labs

I’ve heard some concerns about duplicate efforts between the two entities. This is what I’m doing on my side to avoid them:

Active coordination: I sync weekly with Yemel (Executive Director, Foundation) and Kim (Head of Marketing & Partnerships, Foundation), and regularly with Nico R. (Head of Product, Foundation). Agus (DAO Council member) also advises and attends Foundation board meetings.

Unified ecosystem view: My goal is that by 2026, we operate against a shared ecosystem roadmap, with a clear division of initiatives between the Foundation and Regenesis Labs. We will soon announce the first joint initiative between the two entities.

Knowledge sharing: Hiring Gonzalo Pombo (ex-Foundation SDK team) as Regenesis Director of Engineering shows our commitment to continuity and knowledge transfer.

Independence with alignment: Regenesis must remain an independent entity, learn from what works at the Foundation, and avoid repeating mistakes. My commitment as ED is to minimize overlap, and I expect the same commitment from the Foundation.

Concern 5 — DAO Treasury management strategy

First, it’s important to note that this is the DAO Council’s responsibility. They are the ones to define and communicate it. But because Regenesis is mentioned in their post, I would like to clarify:

  • We don’t set the treasury strategy. That mandate lies with the DAO Council.
  • Our role is to manage the relationship with the third-party provider that implements the strategy, only because we’re the team with a legal entity that can sign the agreement.
  • We will not move DAO treasury funds and will not have direct access to them. Our job is to help the Council and the selected provider implement a safer, more trust-minimized setup than what we have today.

If you want more clarity, have questions or comments, please use the spaces where discussion compounds and is easy to track:

Town Halls (bring questions; I’ll be there)

Forum Topics (for async discussion and permanent record)

Or book me directly over Calendly

Thanks again for your input!

GinoCT

Executive Director, DCL Regenesis Labs

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Hi @ginoct! Really appreciate you taking the time to watch the recording and respond to some of the questions that were raised during our event! There’s one more point I’d like to mention, since it’s been coming up more often in the community: the wish for an organizational chart that makes the DAO’s structure easier to understand.

There is this page:
https://decentraland.org/governance/transparency/

But it’s outdated and neither the Council nor Regenesis Labs are listed there. Is there a plan to update this page or should we expect a different kind of organizational chart in the future?

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You’re right, the page is outdated, and some things are currently broken. The governance platform hasn’t been actively maintained since the former GovSquad Core Unit wound down operations in September 2024. In the last year, they’ve handled essential governance changes and fixes to keep the essential functionality working as we committed, but the engineers have moved on to other projects and don’t have capacity for ongoing upkeep.

Regenesis Labs will assume maintenance of the platform, including updating the org/roles and enhancing the Transparency page. It isn’t our current focus since we don’t have a web development team hired, but we expect to make progress on this in late Q4 2025. I’ll keep everyone posted on this.

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Unfortunately, it is a disappointing answer that did not seriously engage with the proposal we voted on, which only increases my concerns about accountability and professionalism at a time when the community expects clear, transparent reports of funds.

That first thing catch me in your respond to a $1.3M custody failure shows a lack of seriousness. Moving millions with zero safeguards is not a minor oversight — it reflects poorly on the Council’s professionalism and risk standards, and then saying ‘‘ point taken’’.

Right now, it gives the impression of casual transfers between friends rather than the actions of stewards managing a community treasury under strict standards. Even after this risk was raised, the funds have not been returned to the safer Council custody wallet. That lack of urgency to correct such a serious issue leaves me questioning the Council’s ability to manage the DAO’s resources responsibly.

You said the $1.3M was “Council-approved.” Please share the actual vote record (who voted yes/no).

Without this, it looks like: “Hey Council, send me $1M+ to my personal wallet” with no public record for that fund that, meanwhile, I saw transfers for tens of thousands leaving your wallet with no audit or public tracking, unlike the DAO transparency page we used to have. as i requested in DAO Discord ( here)

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The Executive Arm proposal explicitly committed to “regular reporting to the DAO,” including financial disclosures and staff salaries. Quarterly PDFs don’t meet that. What we voted for was monthly expense breakdowns (balances, tx hashes, categories, vendors, aggregate salaries). That’s also consistent with how the DAO has always operated through its transparency page. as i mention in DAO Discord ( here)

Nowhere in your Town Hall diagram or in any proposal did it state that $1.3M would be transferred to a single individual’s wallet that is only yours, with no published monthly budget, salaries, or expense breakdowns. I’ve seen none of those details so far, and according to the proposal, this shouldn’t even be a debate. It was supposed to be clear and transparent from the start. Especially given that there are still only couple employees hired, no heavy workload, and no expenses that justify moving millions into a personal wallet, this looks extremely sketchy. Responsibility falls on both those who sent the funds carelessly and the individual who accepted them without reason.

This is not acceptable answer when Regenesis is managing a $7M+ budget and already moved $1.3M into one individual’s wallet. At this scale, reporting isn’t optional — it’s the first priority.

Funds are leaving with no audit trail or way for the DAO to verify expenses, which goes directly against the Executive Arm proposal commitments.

So I’ll ask directly: what is the due date for proper monthly financial reports (balances, tx hashes, categories, vendors, aggregate salaries)? that should be in days and not even weeks….

Without a clear timeline, it looks like DAO funds are being converted into private money in a closed book — duplicating what the Foundation already does, but without the transparency the DAO was promised.

That doesn’t make you the owner of the DAO treasury, nor does it give you the right to spend it without audits or detailed reporting. These are community funds, and every cent should be accounted for in public reports. The Executive Arm proposal itself committed to regular reporting and financial disclosures — because any sponsor or partner in the world would expect to see exactly where the money goes, and the DAO deserves nothing less.

After waiting 7 months for a “Treasury Management Strategy,” what we got isn’t a strategy at all. It’s one of the weakest I’ve seen , unclear, unprofessional, and missing any numbers. A real strategy should be based on facts and figures, not misdirections and half-truths (as I noted in Discord). Agus has neither the experience nor the background in treasury management, and it shows in this extremely weak proposal — so please don’t call it a strategy.

At the end i want to ask why $1.3M upfront in private wallet?
With only 6-7 hires so far, why transfer such a large lump sum instead of smaller rolling top-ups from the Council multisig every couple months? Did anyone ask for your burn rate or runway plan for each coming month? If you spend 50k/ month as expenses then $150k is enough for 3 months, and not $1.3M.
for now with no dashboard I would ask for :

  • Actual monthly spend (burn rate)

  • How many months of expenses you intend to keep.

  • expenses for all previous monthes

It’s disappointing to see commitments reduced to wordplay while millions sit in a private wallet. The DAO fund deserves transparency and accountability, not excuses. The $1.3M should be returned to the Council custody wallet immediately (as i asked in discord) , keeping, at most, two months of expenses in advance, not $1.3M, Failure to do so will be seen as rejecting a basic safeguard, will deepen concerns, and will completely erase any remaining trust I have in you — which, for me, is already lost with the Council. All responsibility for this situation will rest entirely on the Council and the individuals who signed the transaction to send you that money.

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Hi Rizk,

I’d like to address your recent comments point by point…

Regarding “disappointing answer” and lack of accountability: I’d appreciate if you could substantiate the adjectives you’re using here. Regenesis Labs has demonstrated transparency that significantly exceeds what the Committee provided over the past year. Can you point me to any comprehensive report of Committee activities from the past year for comparison? Actually there is a good chunk of transparency over the Committee activities, and that is mostly thanks to Gino’s leadership of the GovSquad and automated tooling that they built. The Committee’s use of various tools and approaches was never formally “approved” by the community, yet dynamism and execution speed were always valued and praised.

Regarding monthly reporting commitments: You state that the Executive Arm proposal “explicitly committed” to monthly expense breakdowns with balances, tx hashes, categories, vendors, and aggregate salaries. Could you please point to where exactly this monthly cadence was specified in the proposal that was voted on? I don’t recall voting for monthly expense breakdowns.

Regarding the “$1.3M to a single individual’s wallet”: You continue to repeat this point despite Gino having already addressed it comprehensively in his post. Not only has he explained the operational structure and oversight mechanisms, but he’s also taken immediate action based on your feedback by adding a recovery key mechanism. The operational wallet is a standard practice for any operating organization and was part of the original proposal. This isn’t “a single individual’s wallet” (2-of-3 with one person having 2 keys, now it’s 3 different holders of the key) anymore, thanks to you.

Regarding “ownership of DAO treasury” and spending without audits: You state that Regenesis Labs doesn’t have “the right to spend it without audits or detailed reporting.” This fundamentally misunderstands the governance structure that was voted on and approved. Regenesis Labs has operational autonomy to execute on their approved 18-month plan. The Council approved that. The community approved that. One Council member resigned because they felt it was too much bureaucracy to approve that. The Council provides oversight, not micromanagement of daily operations. This is how professional organizations operate. What you’re describing—requiring pre-approval for every transaction– would make it impossible to operate effectively and could lead to all the rest of the Council to resign.

Regarding the “7 months for a Treasury Management Strategy”: Could you clarify what “7 months” refers to? Regenesis Labs has only been operational since… last month? July? As for what constitutes a “proper strategy”—let’s define that. A strategy is a clear, actionable plan to achieve specific objectives. What Gino outlined is exactly that: deposit the majority of funds in low-risk yield farming protocols, maintain sufficient operational cash to avoid forced MANA sales if the price drops below $0.26, and optimize MANA purchases when favorable. This is textbook treasury management for an operational company. It’s simple, transparent, and risk-aware. A great strategy is one that is easily understood and executed—not complex financial engineering documents. If you believe this doesn’t constitute a strategy, could you specify what elements you think are missing?

A pattern that I see in your answer is that you seem to be conflating complexity with competence. Regenesis Labs is executing a straightforward, professional approach to operations and treasury management. That’s exactly what the DAO needs —not more bureaucracy or indiscriminate accusations against the people that are trying to improve the DAO. You’re not even giving them a chance at all!

PS: Edited because I think I was being offensive.

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On strict standards, I would suggest to look how the DAO Treasury is being secured since the Committee is supposedly to be the safeguard of it (And one of the reasons you’re being compensated)

First: I know exactly how the Treasury transparency page works, my team built it.

Second: if there were no public tracking, you wouldn’t be able to see the “tens of thousands” leaving the wallet. (I will save you the calculations: USDT 245,747.87)

Third: Regarding audits, we’re evaluating the best path so it’s an actual audit. Auditing ourselves does not count, if only the Council does, you will say it’s not professional enough.

What you voted for is expense breakdowns and that’s what you will get. Actually, that’s what you’re getting in the dashboard we shared, and you didn’t even mention it in your previous comment. Have you had a look?

It states Regenesis Labs will have a Treasury plus an Operational Wallet. Our projected OpEx for 18 months is ~$1.2M. That’s what was transferred (plus a buffer) from the Treasury to the Operational Wallet.

What makes you think that?

You really think what you’re stating, or are you just angry? All wallets are public, the flows are visible, and we posted a dashboard. That’s not a closed book. Comparing this to Foundation operations isn’t accurate (in any case, the Foundation can run however they want)

Correct. I’m not the owner, I never had access, nor do I want to. Given recent comments, it looks like the Committee is the owner of the Treasury.

Also, if you can audit me (Like you guys are doing), it’s because every operation we did is on the blockchain. We didn’t even use centralized exchanges or OTC deals to swap MANA, even though it would have been more beneficial from a cost perspective, just to be as transparent as possible.

Rizk, I’ve shared with you (literally, shared a link over a call) the draft of the treasury proposal that one of the potential partners extended. I’ve asked for your feedback because I value your insights. Why are you now publicly posting in an infatuated way about this instead of raising your concerns with the Council on the shared private channel the Committee has with them, or offering you help with this?

No one asked for our burn rate or runway plan; we proactively did it and shared it as part of the budget approval process. What the Council posted is a condensed version of all the documents we shared with them.

I already shared that the reason for the transfer is that our OpEx for the next 18 months is around 1.2M (Compensation, equipment, tooling, services) and that we wanted to hold the minimum amount of money we needed to operate under our responsibility. No money that should go into community projects (Grants, funds, not even the marketing budget) was moved from the Treasury shared with the Council.

The reasoning is simple: when we hire people, we want to guarantee we can pay them regardless of DAO politics or delays (Like the one we had in the first month of operations). Stability matters if we’re asking professionals to join.

I have absolutely no issues with transferring funds back to the Regenesis Labs Treasury if the Council thinks that’s needed. As stated above only reason that was done was to make sure our 18-month operational expenses were on our side.

Edit: Grammar and updated calculation

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