[EP3.3] [Executable] Sell ETH into USDC

[EP3.3] [Executable] Sell ETH into USDC

Status Executed
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This proposal executes a swap of 10,000 ETH into USDC, to ensure ENS DAO has enough to cover operating expenses for 18 - 24 months.


The DAO currently keeps almost 100% of its spendable treasury in ETH. While ENS generates protocol revenue in ETH, having so much exposure to a single volatile asset places the DAO in a vulnerable position.

This is a proposal to convert 10,000 ETH into USDC through a Cowswap swap.

10,000 ETH is approximately 25% of the total amount of ETH held by the ENS DAO (wallet.ensdao.eth) and register controller (controller.ens.eth) as of January 18, 2023.

It is hoped that this sale will generate in excess of $13m in USDC. The goal is to ensure that the DAO has enough USDC to cover operations for the next 18 - 24 months.


  1. Call withdraw() on controller.ens.eth (0x283af0b28c62c092c9727f1ee09c02ca627eb7f5)
  2. Call deposit() on WETH9 (0xc02aaa39b223fe8d0a0e5c4f27ead9083c756cc2), sending 10,000 ETH
  3. Call approve(<milkman>, 10000 ETH) on WETH9 (0xc02aaa39b223fe8d0a0e5c4f27ead9083c756cc2)
  4. Call requestSwapExactTokensForTokens(10000 ETH, <WETH9>, <USDC>, wallet.ensdao.eth, <milkman sushiswap 2% price checker>, 0x) on milkman (0x11C76AD590ABDFFCD980afEC9ad951B160F02797)


  • 0xfe89cc7abb2c4183683ab71653c4cdc9b02d44b7 - wallet.ensdao.eth
  • 0x283af0b28c62c092c9727f1ee09c02ca627eb7f5 - controller.ens.eth
  • 0xc02aaa39b223fe8d0a0e5c4f27ead9083c756cc2 - WETH9
  • 0x11C76AD590ABDFFCD980afEC9ad951B160F02797 - milkman
  • 0xA0b86991c6218b36c1d19D4a2e9Eb0cE3606eB48 - USDC
  • 0x00e577093BEA1eb273bc497a61E3F2658369b226 - milkman 2% slippage sushiswap price checker


Address Value Function Argument Value
0x283Af0B28c62C092C9727F1Ee09c02CA627EB7F5 - withdraw
0xC02aaA39b223FE8D0A0e5C4F27eAD9083C756Cc2 10000 ETH deposit
0xC02aaA39b223FE8D0A0e5C4F27eAD9083C756Cc2 - approve guy 0x0b7fFc1f4AD541A4Ed16b40D8c37f0929158D101
wad 100000000000000000000000000
0x11C76AD590ABDFFCD980afEC9ad951B160F02797 - requestSwapExactTokensForTokens _auctioningToken 0xC02aaA39b223FE8D0A0e5C4F27eAD9083C756Cc2
amountIn 100000000000000000000000000
fromToken 0xc02aaa39b223fe8d0a0e5c4f27ead9083c756cc2
toToken 0xA0b86991c6218b36c1d19D4a2e9Eb0cE3606eB48
to 0xfe89cc7abb2c4183683ab71653c4cdc9b02d44b7
priceChecker 0x00e577093BEA1eb273bc497a61E3F2658369b226
priceCheckerData 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

It would be grand to open a discussion as to what those operating expenses are or if there is a budget that needs to be included into this proposal. @khori.eth outlined one in a prior proposal:


There is currently ~$2.46m of USDC in the DAO wallet (wallet.ensdao.eth).

Assuming the DAO can get more than $13m from the auction (10,000*1,300), this would leave the DAO with ~$15.4m in USDC. The minimum bid for this auction is set at $1,300/ETH.

The main USDC expense comes from ENS Labs. ENS Labs receives a daily stream of $11,500 USDC, which amounts to ~$4.2m per year. Over two years, that is ~$8.4m.

The other main source of USDC spending comes from working groups. Working Group spending is not fixed, can be lowered, and often carries forward from one term to the next. This budget would allow working groups to claim up to ~$1.5m in USDC per term between them. This amounts to ~$3m per year and ~$6m over two years.

With these numbers, spending for 24 months would amount to ~$14.4m in USDC.

Assuming we can get an average ETH sell price of $1,300, this would leave the DAO with ~$1m at the end of 24 months if no additional ETH auctions/ sales are conducted.

The ENS Foundation will likely also request annual funds to cover expenses. These expenses are outlined here and amount to ~$42k per year.


I support this, specially because the money is going back to the same wallet, it’s not about budgeting but about divesting intelligently.

I only wonder about the timing. Although a 24h gnosis auction is a good approach to avoid front running it still raises the question on the “right day”.

Maybe using a ricochet.exchange style stream to dca over a couple of months would be wiser?


This is an even worse idea than having pricing in fiat. Converting Ethereum to a stablecoin is admitting the ENS and Ethereum won’t make it. We might as well go centralized now.

“I support this, specially because the money is going back to the same wallet, it’s not about budgeting but about divesting intelligently.”

This is the same as waging a war against someone, then sending them money. That’s structured suicide, not diversification.

This shows how out of touch the DAO is from reality. USDC has a blacklist function, and the US government only needs to put a gun to one man’s head to KYC trap the funds. The DAO will have little recourse to recover the funds in this instance as the ENS token will be considered an illegal security if things get to this point.

Finally, how dare anyone in the ENS choose USDC over DAI. This is absolute evil in this proposal. This needs to be soundly rejected, and anyone in support removed from any participation in the DAO now, and permanently into the future. This is crypto terrorism, and you all should feel very, very ashamed. It is beyond shocking!

Edit: It is acknowledged some funds for the DAO might need to be budgeted for expenses tied to fiat. This is a reasonable discussion, but the DAO expenses tied to fiat should not even approach 1000 ETH, let alone 10k in the next 5 years. There should be a proposal for each an every instance with a direct reason given. Diversification is not a valid reason.

People are pulling numbers completely out of thin air in the DAO, there is no transparency or competence shown by anyone involved to run even a non-profit organization. This post shall serve as further evidence of the incompetence, malice, and intent of the current insiders of the DAO for any regulators into the future. https://archive.is/wip/ykr4e


Thumbs up for the DCA out of ETH move. Maybe someone could come up with a mathematically optimal way to exit the ETH position but does 2K ETH each month for 5 months make sense?


I’m very positive to this as having a runway of USDC will reduce risk with (seemingly) no real downside to ENS or the DAO.


Thanks @James and everyone else who’s been working on this.
I’m glad we’re getting this done.
Maintaining the next 18-24 months opex in stables is very prudent, and the Gnosis auction is a great strategy.


Trading a widely popular and fairly decentralized currency of value for something that can be arbitrarily locked/potentially exploited doesn’t have risk. Agreed there.

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Seems like this large amount is what OTC is for. Adds a trusted counterparty to the mix tho

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DCA > Gnosis Auction

Probably makes sense to get input from Karpatkey - will this Stablecoin amount be handed over to KK team as part of the Endaoment, or just sit idle in the treasury?


The choice to use USDC is dictated by the proposal we passed last year to fund ENS Labs (TNL at the time).
Alisha mentioned that proposal above. It passed last year, [EP2.1] [Executable] Funding True Names Ltd, it outlines that $11,500 worth of USDC is streamed daily to the ENS Labs team to fund the operation.

The DAO wallet literally has to have USDC in it so that the stream contract can deliver it.

I believe James is planning to re-write this and break it up into several smaller Gnosis auctions as a way to DCA the swap.

Yes, it would be good to hear more from Kartpatkey. They did participate a bit in the Twitter space earlier. Their proposal includes a similar swap to USDC, but it also contains several other components that have been contentious and might need more discussion. The thought here is we can decouple this move to get it done soon, so that we can meet budgets now and ensure that the endowment discussion won’t be pressured by the dwindling USDC reserves.


Why do they need money when they already have a bunch of tokens they could sell? There isn’t any active development taking place either. Some open source commits on the libraries, but that should only have bounty costs. GitHub - ensdomains/ens: Implementations for ENS core functionality: The registry, registrars, and public resolvers.

It’s a bunch of standing around and making proposals counter to the ethos of decentralization, liberty, and censorship resistance. I’m bitterly disappointed with people here I respected for long time. Everyone I work with is as well. We are stunned.


Hi All, great discussions here and on the Twitter spaces. As @AvsA and others have mentioned, DCA is the optimal strategy to execute this trade on-chain vs Gnosis auction.

We’ve built a tool to allow DAOs, protocols, and whales to efficiently DCA on-chain in a gas-optimal manner: TWAMM. From the reception on the call by @James and others, it seemed like the best fit for a trade of this size.

I did not want to de-rail the conversation here and therefore made a long-form post here for more details on our tool, background, advantages, risks, etc: TWAMM: on-chain non-custodial DeFi protocol for large asset swaps.

As I mentioned in the Twitter space, our tool is going into audit on January 23, 2023, by SpearbitDAO, and pending a successful audit will be ready by Eth Denver (March 01, 2023). The first pool we plan to deploy will be ETH/USDC.

I understand that there’s hesitation to execute a large trade of this size on a tool that hasn’t been battle-tested, but I’ve addressed the different risks and mitigation strategies in the forum post linked above.

Happy to answer any further questions!

Wasn’t aware of the USDC requirement - if there’s no way to change that another option could be to deposit this amount of stables in 3Pool on Curve and withdraw USDC as need for operations (perhaps something for Endaoment team to handle). This achieves two things:

  • less amount of funds at risk of being blacklisted by Circle (likely a very low risk, but in DAI or 3Pool it’s eliminated)
  • some arguably very safe yield i.e. 1.5% with $500M+ TVL

3Crv option ofc does bring exposure to USDT, just something to be aware of and consider.

less amount of funds at risk of being blacklisted by Circle

This was discussed in the US Financial Services Committee ad infinitum last year in the outgoing house. There are a strong number of representatives who want to get rid of all stablecoins. They know they can demand blacklisting, which is honestly impressive given that in 2021 almost nobody read contracts or understood blacklists take place.

The most common use of the blacklist now has been hacked funds, and also funds sent to wrong addresses. USDT is pretty efficient even and returns stuck funds sent to contracts for a 10% fee, and wrong addresses too if you know the right people.

While you may discount a direct blacklisting of the ENS, it is definitely possible to get wrapped in sanctions or sweeping legislation of DAOs with governance token. The main threat though is simply a KYC mandate for all stablecoin transactions, and making them illegal with a future rollout of a CBDC down the road. They did exactly this almost overnight with the UIGEA, and they are very likely to pull a similar stunt when it comes to stablecoins.

You may counter with the fact the ENS is ‘transparent’ with known directors, but that’s not how this works. In 2006 there were very transparent and fair gambling sites for poker, while in 2023 there is a mess of gambling legislation at the state level in the US, and nothing is good for anyone. It took way longer than anyone expected for even the most basic things to take place, and the fad of poker long moved on.

Putting money, even in DAI is high risk for anything but a short term movement of small funds. There are practical reasons to do this.

  • some arguably very safe yield i.e. 1.5% with $500M+ TVL

The yield of Ethereum will vastly destroy any stablecoin yield by growing as a network. If the ENS makes it, Ethereum does. There are scenarios where the ENS fails, and Ethereum does well, but it doesn’t seem very likely. This is why what is going on here is so shocking. Any basic understanding of risk and economics means you would never suggest this, unless of course you knew it was going to fail, or you had dark motives.

I’d be supportive of DCAing, and your project seems like a great tool for that - but we can’t be its first user with such a large amount of money at stake, particularly prior to an audit.

A Gnosis auction is a straightforward way to do this that will get us a good price - albeit, the equivalent to the spot price on the day. An alternative would be to send the funds to be exchanged to a Gnosis Safe using the Roles Modifier that allows, eg, the metagov stewards to exchange funds and send them back to the DAO; they could then make the trades but would have no access to the funds.

In the interest of not getting tied up in bikeshedding I’d propose we go ahead with the Gnosis auction for now, and find long-term sustainable approaches down the road.


Media is paying attention.

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Yup totally reasonable given your timelines. Look forward to ENS DAO using TWAMMs down the line post-launch!

I’d be an advocate of doing this over a longer period of time. 10000 ETH is quite a bit. I’d also like to know the current performance of the budget spends from various working groups to understand if the currently-utilized budgets are getting the expected results.

Also curious to know the answers to @Ronald’s point - why does ENS Labs need $11,500 per day? (4 million per year)