Safe investor Greenfield files Swiss ESA complaint over Foundation governance

Greenfield Capital, an early investor in Safe and one of the Ecosystem Foundation's largest token holders, filed a formal complaint with Switzerland's Federal Supervisory Authority for Foundations (ESA) on October 4, alleging governance failures at the Safe Ecosystem Foundation. The filing follows what Greenfield says were months of unsuccessful direct negotiations and comes as Safe's reported assets have fallen from roughly $6.6 billion to $3 billion while the broader DeFi market expanded.

What was filed

Greenfield submitted the complaint to the ESA — the regulator with statutory oversight of Swiss foundations — asking it to compel structural changes at the Safe Ecosystem Foundation, according to Cointelegraph's reporting on the filing. Greenfield founding partner Jascha Samadi published an open letter to the Safe community the same day. The firm is one of Safe's 2022-round investors and has not sold any of its SAFE tokens since.

The complaint seeks board restructuring, the appointment of independent directors, and a strategy review with measurable performance indicators, per Crypto Briefing's write-up of the open letter.

The allegations

Three threads run through Greenfield's filing:

• Board composition. The firm alleges the Safe board at times operated with only two members, which it says breaches the statutory minimum under the foundation's charter.
• Conflict of interest with Gnosis. Board member Stefan George is Gnosis CTO; Gnosis co-founder Martin Köppelmann sits in the surrounding ecosystem. Greenfield says the overlap creates product-level conflicts between Gnosis's wallet lineup and Safe.
• Post-Bybit pressure. After the February 2025 Bybit hack, which routed through Safe's self-custody tooling, Greenfield claims George and Köppelmann pressured Safe co-founders to reallocate significant SAFE token amounts, allegedly threatening that Gnosis would divest its roughly 10% stake if they refused.

What the Foundation did in response

Safe's board filled recent vacancies and set up a strategy committee, but Greenfield characterises the committee as powerless and the response as insufficient — the proximate reason the firm escalated to the ESA.

Why it matters

Switzerland hosts many of DeFi's largest foundations (Ethereum, Solana, Polkadot, Cardano, Safe, Lido) because its foundation law lets a non-profit vehicle own protocol treasuries and employ development teams at arm's length from any single corporate backer. The ESA has broad statutory power to intervene when a foundation's governance drifts from its charter. A regulator-ordered board change at Safe would be the first time that mechanism bites a top-tier crypto foundation in a dispute brought by a token-holder investor — a template other DAOs are watching.

What to watch

1. The ESA's intake decision. The regulator decides whether to open a formal review; the base rate for action on investor complaints is low, but foundations with material public assets attract scrutiny.
2. Safe treasury disclosure. The $6.6B → $3B figure in Greenfield's letter covers the full foundation balance sheet, not just SAFE. Any clarifying statement from the Foundation would reset the public dataset.
3. SAFE token holder response. Governance posts on the Safe forum are the signal to track; a token-weighted no-confidence proposal would be the DAO-side counterpart to the Swiss filing.
4. Precedent for the Ethereum, Solana, and other Swiss foundations. Any ESA action — even a procedural inquiry — would be read as a general template.

Context

Investor-led regulator complaints against foundations are rare in crypto; the usual escalation path is a DAO vote or an on-chain governance attack. Greenfield's filing routes outside the DAO entirely, treating Safe's foundation as what Swiss law says it is: a legal entity bound by its charter and accountable to a regulator, not just to its token holders.