While Su Zhu, a co-founder of bankrupt crypto hedge fund Three Arrows Capital (3AC), announced Thursday that a waitlist is live for Open Exchange (OPNX), the new exchange may not be as open as its name implies.

The newly announced venture caters to those who’d like to trade bankruptcy claims—in cases from FTX to Blockfi—but stipulates on its homepage that people in 23 different regions are barred from signing up.

Those countries include sanctioned nations such as North Korea, Cuba, and Venezuela, but the United States is also listed as one of OPNX’s restricted regions. That’s despite some of the biggest bankruptcies currently playing out in the crypto space concerning companies based in the U.S., such as Genesis, BlockFi, Celsius, and Voyager Digital.

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When Zhu unveiled the new exchange on Twitter, he stated “trapped creditor claims from FTX, Voyager, Celsius” were part of the creative spark behind OPNX, raised in conversations with CoinFLEX co-founder and CEO Mark Lamb. “It clicked for both of us at exactly the same moment,” Zhu wrote.

A leaked pitch deck for the exchange—previously called GTX—showed Zhu, Lamb, 3AC co-founder Kyle Davies, and CoinFLEX co-founder Sudhu Armugan sought to raise $25 million for the new venture.

One of the pitch deck’s central claims was that it will “fill the power vacuum left by FTX” and “appeal to the crypto trading appetite of claim holders.” But U.S.-based residents who were customers of FTX US appear barred, which totaled 1.2 million by the beginning of 2022, according to the exchange’s ex-president Brett Harrison.

3AC imploded last summer after sustaining heavy losses from the collapse of the Terra ecosystem. It was once one of the largest crypto-centric hedge funds when it collapsed and is based in Singapore, which is not on the restricted regions list.

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Crypto exchange CoinFLEX, while headquartered in Hong Kong, filed for restructuring in Seychelles last year. Neither of those regions is restricted to prospective customers of OPNX either.

Zhu said that CoinFLEX’s native token FLEX will be the “primary token of the new exchange,” which popped as high as $1.61 following the announcement, according to CoinGecko data. As of this writing, it was down roughly 12% to $1.15.

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