[ARFC ADDENDUM] Mandatory Disclosures and Conflict-of-Interest Voting Norms

Governance General
36

On-Chain Analysis of the NAY Vote on the [ARFC ADDENDUM] Mandatory Disclosures and Conflict-of-Interest Voting Norms

A proposal that requires disclosure of voting addresses is being blocked by undisclosed, interconnected voting addresses.

Disclosure: ACI is a service provider to the Aave DAO. We have skin in the game on governance transparency. Judge the evidence, not the messenger.

TL;DR

Total: 592K VP of NAY, ~99% of the NAY side, traceable to Aave Labs and Stani infrastructure. None of it disclosed.

Vote status as of Feb 12 12:30 UTC: NAY 600K vs YAE 538K. 128 voters, four addresses decide the outcome. Closes February 13. Snapshot

The Four NAY Addresses

Address Voting Power Source
0xEA0C12Fd29c3fe5B1ecC82a42702196bd0De6B5A 333,000 100% delegated stkAAVE
0xdC0990910F47aD479020eD77B0d62BF738C2791a 111,885 Self-held (3,567 AAVE + 108,318 stkAAVE)
0x2764f4F458f5B2d44Cc817468777F665e1261FAa 106,282 100% delegated stkAAVE
0x58dDfB3Db792d2f8E2cdd5ba9726e6b932a3f5aF 40,880 100% delegated stkAAVE

0x2764f4F458f5B2d44Cc817468777F665e1261FAa and 0x58dDfB3Db792d2f8E2cdd5ba9726e6b932a3f5aF have zero outgoing on-chain transactions, no token activity. Their only function: receiving delegation and signing Snapshot votes.

Finding 1, 333K VP, same signers as the AAVE Multisig

The 333,000 stkAAVE delegated to 0xEA0C12Fd29c3fe5B1ecC82a42702196bd0De6B5A comes from Safe 0x8cd291a587d7961682d5763cc0a2efd094e8b15d, configured 3/7.

The Nansen-labeled AAVE Multisig 0x507b3f6d4f85c451f7914006c647391a1afb96d6 has the same seven signer addresses and the same 3/7 threshold.

The signer sets match exactly on-chain.

Finding 2, 41K VP, Stani-labeled Safe to ghost voter

The 40,879 stkAAVE delegated to 0x58dDfB3Db792d2f8E2cdd5ba9726e6b932a3f5aF comes from 0xe705b1d26b85c9f9f91a3690079d336295f14f08, labeled by Nansen as “Stani Kulechov, Public Figure, Gnosis Safe.”

Finding 3, 112K VP whale, funding path and ENS trail

0xdC0990910F47aD479020eD77B0d62BF738C2791a votes with 111,885 VP from self-held tokens. Two Snapshot votes in its entire history, both NAY, both on proposals affecting Aave Labs.

Funding chain via Nansen:

0xdC0990910F47aD479020eD77B0d62BF738C2791a ← 0xc4a936b003bc223df757b35ee52f6da66b062935 ← 0x0a82e6ef40cfcca9d5f651292194aa1c7fb2f9f4 (Nansen: Aave Liquidation Account)

Cross-chain link:

ENS proof from archival state:

  • At block 9,800,000, the old ENS registrar deed for kulechov.eth resolves to deed owner 0xDaC706632A11379f707A12E036B9Aae89Af20F1d. On-chain ENS registry data, not a Nansen label.

  • The same address held cryptolawyer.eth, consistent with Stani’s Master in Law from the University of Helsinki and his traineeships at law firms Castrén & Snellman and Bird & Bird.

  • Also held rarecars.eth and other personal domains.

  • Held 68,638 LEND at block 11,000,000, pre-AAVE migration era.

The whale’s funder 0xc4a936b003bc223df757b35ee52f6da66b062935 was funded by the Aave Liquidation Account 0x0a82e6ef40cfcca9d5f651292194aa1c7fb2f9f4, held millions of LEND pre-migration, and interacted with Aave V1 Lending Pool Core 0x3dfd23A6c5E8BbcFc9581d2E864a68feb6a076d3.

Finding 4, 106K VP, fresh Safe linked back to Finding 1

The 106,282 stkAAVE delegated to 0x2764f4F458f5B2d44Cc817468777F665e1261FAa comes from Safe 0x6a4db4b375592a1fa59af7579d8aba8a46513402.

Chronology:

On-chain signer verification:

Nansen independently labels 0xaed37c48a5e3d8edeefc413c44a56fd2f8c1886a as AAVE Multisig and signer 0xe7a4f2b1772603170111bc633cbcf1acebd60bce (present in all three multisigs, 778 transactions, active since 2020) as Aave Deployer.

Beyond this vote

If a single compensated service provider can deploy ~600K VP through undisclosed wallets to block a governance reform, that capability applies to everything: budgets, service provider elections, protocol upgrades.

Formal decentralization means nothing if one entity can silently veto proposals through wallets nobody knows they control. The on-chain record shows this just happened, on a vote about whether such connections should be transparent in the first place.

I have previously called this dynamic a slow motion coup. This analysis is the evidence.

The same cluster voted as a block on the AAVE Token Alignment proposal in December 2025. Same ghost addresses, same delegation structures, same undisclosed coordination. A pattern, not an incident.

Closing

On-chain votes remain valid under current rules. The issue is undisclosed control.

The record shows 592K NAY VP from interconnected wallets tied to one service provider, voting against a proposal that asks controllers of voting power to disclose their addresses.

If Aave Labs disputes this analysis, the simplest rebuttal is to publish the full list of voting addresses under their control. That is, after all, exactly what this proposal asks for. If these wallets are not theirs, transparency costs them nothing. If they are, then this vote has made the case for mandatory disclosure better than any proposal text ever could.

Vote closes February 13. The data is on-chain. Every address in this post is verifiable.

ACI is a service provider to the Aave DAO. This analysis uses on-chain transaction data, archival Ethereum state, and Nansen Pro labels. All referenced addresses are independently verifiable.

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