How TON Ecosystem Reserve legitimized 531M TON mined by Telegram's orbit under the guise of a "community donation"
On April 7, 2022, TON Foundation launched TON Ecosystem Reserve under a 3-of-5 multisig, promising TON product integrations, community growth, and partnerships. On April 21, an official TON channel called it a record $1B raise and thanked whales who gave TON "without asking for anything in return."
This was not a broad community raise. Nineteen Large Giver miner wallets in a linked cluster contributed 420.32M TON directly. Another 17 linked wallets sent 106.9M to Reserve. Fifteen transferred at least 99.99% of their balances, while two sent 98.98% and 98.89%. Another wallet contributed 4M after receiving 29.27M from a Large Giver miner. The same miner funded an early TON-project payout wallet. Together, 37 linked early-mining wallets supplied 531.22M TON - 99.99% of Reserve inflows. On September 12, 2023, seven Reserve donors and another early miner sent 374.99M to one TON Foundation wallet, from which 353.32M went to Telegram.
On November 3, 2023, after an announced address migration, all 531.22M TON moved from the 3-of-5 multisig to a single-key wallet. The controller and reason for reducing control to one key were not disclosed. TON Space, TOP, Web3 Grants, and Telegram integration had already been announced. No Reserve outflow to any of those programs occurred before the migration.
From July 28, 2025, 283M TON left Reserve. At least 218.25M went to Telegram - 77.12%. Another 20.23M reached a TON Foundation payment hub. Of 30M sent to eight validator pools, 23.84M returned and 6.15M remained outside Reserve. Two pools remain active. On August 2, another 5M left Reserve: 1.89M went to OKX and 3.09M entered a Binance route. Later sweeps exposed its endpoint - 58F1 -> 1D0A, 1D0A -> 20D7, and 20D7 -> Binance Hot Wallet. Another 2M TON went to a new wallet and remains there. Reserve holds 248.22M.
On July 29, one day after the first 100M TON withdrawal, Telegram received 27.51M and 27.43M. On July 31, it signed an agreement with TON Strategy. On August 8, Telegram transferred 149.01M TON to TON Strategy in five material transactions under the $272.7M agreement (1, 2, 3, 4, 5). Because the funds were commingled, the exact Reserve share of that package is 0-54.95M TON. The full 54.95M reached Telegram two days before the agreement.
The Open Network Stiftung did not exist during the raise - it was registered on May 3, 2023. The 2022 legal recipient and any transfer of 531.22M TON to the Stiftung were not disclosed. Article 84 of the Swiss Civil Code binds foundation assets to their purpose. If Swiss law governs the gifts and the April promises were accepted conditions, Articles 246 and 249 of the Swiss Code of Obligations allow a donor to demand performance or, after breach, revoke the gift and recover the remaining enrichment. No agreement, valuation, board resolution, or accepted deliverable was published for Telegram's 218.25M. Criminal liability requires proof of a breach of asset-management duty and resulting loss. If the offender acted with a view to securing an unlawful financial advantage for themselves or another, Article 158 of the Swiss Criminal Code provides that a custodial sentence of one to five years may be imposed.
No donor publicly demanded a budget, a result, or the return of the gift. Links among Large Giver miners and the near-total balance transfers show these were not 37 unrelated donors, but a connected early-mining cluster linked to Telegram's orbit. Telegram received 218.25M of the 283M TON withdrawn - 77.12%. TON Foundation has named no promised integration, growth campaign, or partnership funded by those 283M TON. In Telegram's wallet, Reserve inflows mixed with the rest of its treasury. From that pool, Telegram sold TON, moved funds to Fragment, and placed 200M across 52 validators to earn rewards. The "community donation" legitimized supply mined by Telegram's orbit as a liquid asset for sales and recurring income.
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