CoW Protocol is a decentralized trading protocol on Ethereum and other EVM chains that lets users trade ERC-20 tokens without paying MEV (front-running, sandwiching, etc.) and frequently get prices better than what's available on any single venue. Instead of routing trades directly to AMMs, users sign an intent "I want to sell at least X of token A for at most Y of token B" and a competition of independent third parties called solvers compete to find the best execution path on the user's behalf. Solvers can match a user's trade peer-to-peer with another user trading in the opposite direction (a "Coincidence of Wants - CoW" hence the name) or, if no match exists, settle the trade through either on-chain liquidity sources like AMMs and aggregators or offchain liquidity. The winning solver in each batch must give every user at least the price they signed for, and part of the extra value (surplus) found by the solver flows back to users. Trades only settle when the user gets what they asked for or better; the protocol never custodies user funds in transit. CoW Swap is the flagship user-facing product built on top of CoW Protocol. CoW DAO also develops adjacent user-protective products including CoW AMM (an MEV-capturing automated market maker for liquidity providers) and MEV Blocker (an RPC endpoint that protects regular Ethereum transactions from MEV), which was sold to Consensys in early 2026.

Labs / DevCo

Foundation

Business Co (CoW Business Limited and the broader operational entities)

Foundation

DAO/Onchain Governance CoW DAO has no named officers. Governance is conducted by COW token holders via:

• The CIP (CoW Improvement Proposal) process: proposals are discussed atforum.cow.fi and voted on via Snapshot at cow.eth.
• The Participation Agreement (CIP-1) which functions as CoW DAO's foundational constitutional document.
• A set of Safe multisigs (see Section 11) that execute approved proposals. Four Delegated Committees, each established by their own CIP, hold ongoing operational mandates from the DAO:
• Grants DAO Committee (CIP-63) — administers grants distributions
• Treasury Committee (CIP-62) — manages treasury yield strategy and asset deployment
• Legal Defense Committee (CIP-50) — manages the Defense Reserve and legal protection of the protocol and its contributors
• CoW Team Grant Allocation Committee (GIP-13: “Should Gnosis DAO proceed and deploy CowDAO and vCOW token?”);

(a) IP ownership & control

All Intellectual Property Rights originating from or related to CoW DAO — including the CoW Protocol smart contracts, the CoW Swap brand and trademarks, the CoW AMM and brands, and any IP created since CoW DAO's inception (per Article 12 of the Participation Agreement) — are owned unequivocally and perpetually by CoW Foundation unless they are open source, in which case the relevant open-source licence applies. This ownership extends to all future IP created by or on behalf of CoW DAO. The smart contract codebases at github.com/cowprotocol are open-source under permissive licenses (Apache 2.0 / GPL — varies by repo) but the underlying IP rights and trademarks are held by the Foundation.

(b) Contract/admin powers

The protocol's settlement contract (GPv2Settlement) and operational infrastructure are controlled by CoW DAO via Safe multisigs that execute Snapshot vote outcomes:

• The CoW DAO main safe (0xcA771eda0c70aA7d053aB1B25004559B918FE662 on Ethereum) is bound to cow.eth Snapshot vote outcomes; this safe's multisig signers were unaltered by the entity restructuring per the Mooderator CIP. Threshold 3/5.
• The Solver Voucher multisig (0x423cEc87f19F0778f549846e0801ee267a917935) adds and removes solvers from the settlement contract's allow-list per DAO-defined bonding rules. Operational responsibility for solver vetting, allow/deny lists, and the bonding pool is delegated to CoW Core Limited. Threshold 4/15.
• The Solver Payouts safe (0xA03be496e67Ec29bC62F01a428683D7F9c204930) executes solver rewards per CIP-20. Operational responsibility for payout calculation and execution sits with CoW Business Limited (which manages all protocol-related payments). Threshold 4/11.
• The Operational CoW DAO Safe (CIP-43) is owned by the CoW Foundation, which mandates the Core Team and Operator on operationalisation, including the bug bounty program, ETH funding flows, and other smart contracts. Authority threshold for all such actions: COW token holder majority via Snapshot, with execution by the relevant multisig. Proposals require a minimum quorum of 35M COW tokens voting.

(c) Locked-token rights (conditional)

No locking or staking mechanism for additional governance rights currently exists. COW is a pure governance token; voting is conducted off-chain via Snapshot and is weighted by COW (and vested-but-unclaimed vCOW) balance at the snapshot block.

(d) Current tokenholder governance rights and economic arrangements

Current rights of COW token holders, exercised via Snapshot at cow.eth:

• Approval / rejection of CIPs covering protocol parameters, treasury actions, fee policies, solver bonding rules, partner agreements, and grants.
• Authority to appoint or remove the Director of each entity in the legal structure (Foundation, CoW Core, CoW Hosting, CoW Business) and to appoint or remove the Supervisor of the Foundation.
• Authority to amend, expand, or wind down the entire 4-entity legal structure or any part of it.
• Direction over treasury actions, fee routing, and solver reward parameters via CIPs. Currently operative economic arrangements include token buybacks — CIPs 36 and 48 authorize COW token buybacks executed by CoW Business Limited through market transactions. This is an active programmatic mechanism by which protocol-controlled resources flow back to the COW token / market. Buyback methodology is based on weekly revenue-funded buybacks in the open market through TWAPs. Operation is operationalised by the Core Team which has a DAO mandate to buyback entirety of solver rewards emitted in the week, with a mandate to buy up to 120% solver rewards. Buyback performance can be reviewed on Dune.

(e) Control surface reliance

Following the Mooderator CIP-64, CoW DAO's control surface is structured as follows: CoW DAO (unincorporated, on-chain) sits at the top and remains the ultimate decision-maker. The CoW Foundation acts as CoW DAO's legal interface to the real world and is the sole member/guarantor of CoW Core Limited and CoW Hosting Limited, and the sole shareholder of CoW Business Limited. The Foundation's director is a natural person; the directors of the three subsidiary entities are the Foundation as a corporate director. CoW DAO retains the power to appoint or remove the directors of each entity and to amend each entity's mandate. The settlement contract, COW token supply, tokenomics framework, and governance remain unwrapped — they are not attributed to any of the legal entities and are governed exclusively by CoW DAO via Snapshot. Where parts of the protocol or infrastructure become sufficiently decentralized, the relevant entity may propose to the Foundation that the corresponding mandate be moved back to CoW DAO; the Foundation in turn proposes such changes to CoW DAO via governance mechanism.

(f) Dissolution authority

The legal structure can be wound down in whole or in part by CoW DAO via the governance mechanism (Snapshot vote at cow.eth):

• CoW Foundation: dissolved by governance mechanism.
• CoW Core: dissolved by governance mechanism.
• CoW Hosting: dissolved by Director and/or governance.
• CoW Business: dissolved by Director and/or governance. On asset disposition:
• CoW Business assets flow to the Foundation (its sole shareholder).
• CoW Core and CoW Hosting assets are donated to the Foundation per their incorporation documents.
• Foundation financial assets are transferred to a DAO-owned wallet as directed by governance. The Foundation is intended to be the final entity dissolved if CoW DAO opts to wind down the entire structure. The Mooderator CIP authorizes the relevant Directors to wind down CoW Hosting and CoW Business unilaterally for the strict purpose of legal or regulatory compliance, as outlined in those entities' bylaws.

(a) Entity

Cayman Islands Company Foundation, shareholder-less and member-less.

(b) IP ownership & control

CoW Foundation owns all Intellectual Property Rights originating from or related to CoW DAO, perpetually and unequivocally — including the CoW Protocol smart contract codebase, the CoW Swap, CoW AMM, brands and trademarks, and all IP created since CoW DAO's inception per Article 12 of the Participation Agreement (CIP-1), as well as any future IP created by or on behalf of CoW DAO. The Foundation has three subsidiary entities in the legal structure:

• CoW Core Limited (BVI, Company Limited by Guarantee) — Foundation is sole member and guarantor; corporate director.
• CoW Hosting Limited (BVI, Company Limited by Guarantee) — Foundation is sole member and guarantor; corporate director.
• CoW Business Limited (BVI, Limited Liability Company / Company Limited by Shares) — Foundation is sole shareholder; corporate director.

(c) Powers over DAO, treasury, protocol-controlled resources, and token administration

The Foundation is mandated by CoW DAO to act as the DAO's legal interface; it does not itself have unilateral authority over DAO governance. Specifically:

• The Foundation manages CoW DAO's financial assets through the Treasury Committee (CIP-62) — this is a delegated mandate, not unilateral authority.
• The Foundation administers grants distributions either directly or through the Grants DAO Committee (CIP-63).
• The Foundation owns the Operational CoW DAO Safe (CIP-43) and mandates the Core Team and Operator to operationalize it (bug bounty, ETH flow funding, smart contracts).
• The Foundation has no authority over the COW token supply or the settlement contract; these remain unwrapped and under direct DAO control.
• All major decisions ultimately require CIP approval; the Foundation's role is to formalize and execute, not originate, those decisions. The Foundation also coordinates the allocation of tasks resulting from approved CIPs across the legal structure (in coordination with the Core Team), assigns CIP-58 mandates to the relevant new entities.

(d) Powers over DevCo

The Foundation is the corporate director of CoW Business Limited (the operational/business entity) and the sole shareholder of that entity. In that capacity, the Foundation can direct CoW Business's day-to-day affairs within the bounds of the mandates CoW DAO has set via CIPs. Operational freedom rests with CoW Business's director (which is the Foundation as corporate director) for routine matters; material changes to mandate or scope require CIP approval.

(e) Contract/admin powers

The Foundation does not hold direct admin keys over the production settlement contract or the COW token contract; those remain under DAO multisig authority. The Foundation owns and operates:

• The Operational CoW DAO Safe (CIP-43).
• The Defense Reserve (post-migration per CIP-50).
• Most non-developer tooling (for cross-entity coordination).
• Community management tools and infrastructure. Director appointment / removal threshold: COW token holder majority via Snapshot. Supervisor authority: the Supervisor may remove the Director for gross negligence, may initiate independent investigations, and is obligated to respond to concerns raised by interested parties. The Supervisor itself is appointed and removed by CoW DAO governance.

(f) Current economic arrangements and distribution policies

The Foundation may generate treasury yield on assets under management and receives profit generated from its three related entities to be included in the treasury management mandate. The Foundation in turn allocates funding to all entities of the structure to pursue their respective activities. The Foundation is the recipient of asset value upon wind-down of any subsidiary entity (CoW Business assets revert to Foundation as shareholder), of CoW Core and CoW Hosting assets, to be donated to Foundation per their constitutions. Upon wind-down of the Foundation itself, financial assets are transferred to a DAO-owned wallet per governance direction. The active COW buyback program (per CIPs 36 and 48) is executed by CoW Business Limited via market transactions, but the broader treasury management framework — including which tokens are accumulated, deployed for yield, or used for buybacks — sits within the Foundation's mandate and the Treasury Committee's delegated authority. No dividends, repurchases of equity, or other distributions to natural persons or external equityholders currently exist.

CoW Foundation

(a) Entity

5.1 CoW Core Limited British Virgin Islands Company Limited by Guarantee. Sole guarantor: CoW Foundation.

5.2 CoW Business (Business focused adjacent entity) British Virgin Islands Limited Liability Company, organized as a company limited by shares. Sole shareholder: CoW Foundation.

(b) IP ownership & control

5.1 CoW Core Limited CoW Core does not own protocol IP. All IP rights are held by CoW Foundation. CoW Core conducts development and assigns IP (where not open source) to the Foundation

5.2 CoW Business (Business focused adjacent entity) CoW Business does not own protocol IP. All IP rights are held by CoW Foundation. CoW Business operates the commercial relationships (CEX listings, market makers, partner integrations, fee agreements per CIP-61) but the underlying brand and code IP sits with the Foundation.

(c) Powers over DAO, treasury, protocol-controlled resources, and token administration

5.1 CoW Core Limited CoW Core operates strictly under mandates issued by CoW DAO via the governance mechanism. It has no unilateral authority over DAO governance or token administration. Within its mandate, it manages:

• Solver reward calculation.

5.2 CoW Business (Business focused adjacent entity) CoW Business operates strictly under mandates issued by CoW DAO via the governance mechanism. It has no unilateral authority over DAO governance or token administration. Within its mandate, it manages:

• The Payout Safe and Protocol Fee Safe (operational management; ultimate authority over funds rests with the DAO).
• Solver reward calculation and distribution per CIP-20.
• COW token buybacks per CIP-36 and CIP-48 (via market transactions).
• MEV Blocker–related payments.
• Negotiation and signing of fee agreements with partners on behalf of CoW DAO under CIP-61.
• CEX listing and market maker relationships.

(d) Powers over Foundation

5.1 CoW Core Limited None.

5.2 CoW Business (Business focused adjacent entity) None. CoW Business is wholly owned and corporate-directed by CoW Foundation; the relationship runs the other direction.

(e) Contract/admin powers

5.1 CoW Core Limited It does not hold pause/upgrade authority over the settlement contract or COW token. Director: CoW Foundation as corporate director.

5.2 CoW Business (Business focused adjacent entity) CoW Business operates the Payout Safe and the Protocol Fee Safe, and executes buybacks and partner-related payments. It does not hold pause/upgrade authority over the settlement contract or COW token. Director: CoW Foundation as corporate director.

(f) Current economic arrangements and distribution policies

5.1 CoW Core Limited CoW Core is funded by allocations from CoW Foundation per the legal structure's annual operational budget (auto-renewing yearly; total estimated $338,333/year the Director has discretion to exceed budget by up to 10% and to re-allocate between entities). No dividends or distributions to natural persons are currently in operation.

5.2 CoW Business (Business focused adjacent entity) CoW Business is funded by allocations from CoW Foundation per the legal structure's annual operational budget (auto-renewing yearly; total estimated $180,000/year across the entire 4-entity structure for years following 2025; the Director has discretion to exceed budget by up to 10% and to re-allocate between entities). Revenue collected by CoW Business (e.g., partner fees, protocol service fees) flows back to the Foundation as profit to be included in treasury management. No dividends or distributions to natural persons are currently in operation. The entity assumed activities formerly performed by Defou under CIP-59. Defou's mandate was terminated as part of the Mooderator CIP. Accumulated funds from Defou, net of tax provisions, were donated to CoW Foundation.

CoW Core Limited & CoW Business

(a) Identity & role

APC #1: Karpatkey Karpatkey, a DAO treasury management organization. Role: provides treasury management services to the CoW Treasury safe (0x616dE58c011F8736fa20c7Ae5352F7f6FB9F0669) to generate yield on idle treasury funds, in coordination with the Treasury Committee (CIP-62) and now under the Foundation's treasury management mandate.

APC #2: Leeward Management Limited Leeward Management Limited, a Cayman Islands corporate services firm. Role: (i) provides the natural-person Director for CoW Foundation, (ii) serves as Secretary of the Foundation (handling secretarial work and AML for funds received), and (iii) was mandated by the Mooderator CIP to incorporate the four legal entities on behalf of CoW DAO.

APC #3: Leeward Supervisors Limited a Cayman Islands supervisory service provider. Role: (i) acts as Supervisor of CoW Foundation (independent oversight of director activities and compliance with the Articles of Association; authority to remove the director for gross negligence and to initiate investigations independently).

APC #4: Lemma Solutions Lemma Solutions, a Cayman-based service provider. Role: covers operational needs of the legal structure, including bookkeeping, transaction initiation, agreement support, multisig creation and operational coordination with the Delegated Committees, and (per the Mooderator CIP) production of a regular community transparency report modeled on Balancer's transparency reporting.

(b) Parameter control & scope

APC #1: Karpatkey Karpatkey does not control protocol parameters. Its scope is limited to treasury yield strategies executed within the bounds of the Treasury Committee's CIP-mandated authority.

APC #2: Leeward Management Limited No protocol parameter control. Authority is limited to corporate secretarial, AML, and director duties as set out in the Foundation's incorporation documents.

APC #3: Leeward Supervisors Limited No protocol parameter control. Supervisory authority over the Foundation's director.

APC #4: Lemma Solutions No protocol parameter control. Operational and bookkeeping scope only.

(c) Contract/admin powers

APC #1: Karpatkey Co-signer on the CoW Treasury safe (threshold 3/5). The treasury strategy - investment policy statement - is public and regularly updated as part of Karpatkey’s ongoing communication. Karpatkey is one part of the treasury committee and does not unilaterally control strategy or allocations.

APC #2: Leeward Management Limited No on-chain admin authority. Director-level authority over CoW Foundation, exercisable subject to oversight by the Supervisor and removability by CoW DAO governance.

APC #3: Leeward Supervisors Limited None on-chain. Off-chain supervisory authority as described.

APC #4: Lemma Solutions No on-chain admin authority over the protocol; involved in operational multisig creation and management within mandated scope.

(d) Compensation and material economic arrangements

APC #1: Karpatkey Karpatkey is currently remunerated with a hybrid fee that has a part of fixed services and a part for a percentage over an hurdle rate per type of asset. This model has been negotiated privately in order to reduce the total cost versus prior approved amounts under CIP.

APC #2: Leeward Management Limited Fee-for-service via the operational budget allocated by CoW DAO under CIP-58 and the auto-renewing annual operational budget.

APC #3: Leeward Supervisors Limited Fee-for-service via the operational budget.

APC #4: Lemma Solutions Fee-for-service via the operational budget.

(a) Launch supply totals

• Total tokens issued at TGE: 1,000,000,000 vCOW (1 billion).
• Tokens locked at TGE: vCOW (the vesting representation of COW) issued to team, advisors, early investors, CoWmunity Investment participants, and GnosisDAO vests linearly over 4 years from deployment. The 44.4% DAO Treasury allocation and the 10% CoWmunity Airdrop were not subject to the 4-year linear vest.

(b) Recipient categories & use of funds

(c) Initial price per token

$0.15

(d) Ticker / market symbol

COW.

(e) Total supply & supply regime

• Total supply at TGE: 1,000,000,000 COW.
• Supply is not strictly fixed: the COW token contract permits the CoW DAO to mint up to 3% of the total supply per year as inflation, with a minimum frequency of once every 365 days.

(f) Initial vesting / release schedules

• vCOW (the virtual vesting token) was distributed at TGE to team, advisors, early investors, and GnosisDAO. vCOW vests linearly over 4 years from deployment and is convertible 1:1 to COW once vested. The full unlock schedule concludes on Feb 12th,

• DAO Treasury, and CoWmunity Airdrop, were not subject to the 4-year linear vest, or remaining cliff.

Team token compensation — Under CIP-83, CoW DAO approved replenishing the CoW Team Grant Allocation with 50M COW (5% of the 1B total supply), delivered as a four-year linear streaming allocation from the DAO treasury with no cliff. Individual grants are attributed by the CoW Team Grant Allocation Committee to contributors on standard four-year vesting plans. Separately, a Performance-Based Incentive Tier of up to 100M COW (10% of total supply) can be unlocked in four equal 2.5% tranches upon hitting CoW Protocol annualized-revenue milestones (RunRate = monthly Dune-reported revenue × 12, USD or ETH denominated); these milestone tokens are not subject to vesting. Milestone #1 (50M... i.e. 2.5%, 25M COW) was triggered on Feb 2026 revenue.

Beyond the initial 0.6% CoW Advisory allocation distributed at TGE on a 4-year linear vest to strategic advisors, no ongoing token-based advisory billings or commitments exist. The current external service providers under the legal structure, Leeward Management Limited (corporate services and Foundation Director/Secretary), and Lemma Solutions (operations and bookkeeping) are compensated in fiat from the operational budget, not in COW tokens.

CoW DAO does not engage KOLs or influencers under arrangements that involve token-based compensation. Marketing and community outreach is conducted by CoW Foundation (community management and ecosystem promotion) and CoW Business Limited (commercial marketing tied to partner relationships) using fiat resources from the annual operational budget. Any creator partnerships do not include COW token payments. CoW DAO has implemented, under CIP-84, a paid affiliate program, under which referrers and providers of volume get a revenue split of Fees that the DAO generates.

The vCOW vesting contracts (0xD057B63f5E69CF1B929b356b579Cba08D7688048 on Ethereum, 0xc20C9C13E853fc64d054b73fF21d3636B2d97eaB on Gnosis Chain) hold the unvested vCOW supply that converts 1:1 to COW upon vesting.

CoW Business Limited has the mandate to manage market maker relationships ("CEX Listings & Market Making: Manages relationships with centralized exchanges and Market Makers").

No agreements with centralized or decentralized exchanges exist that involve a COW token allocation, lockup, or native-token listing fee. CEX listings for COW were not contingent on token-based payment from CoW DAO.

(a) Token repurchases or secondary-market accumulations (if any)

Active program. CoW DAO operates a COW token buyback program authorized under CIP-36 and CIP-48. Buybacks are executed by CoW Business Limited through market transactions.

• Buyback methodology is based on weekly revenue-funded buybacks in the open market through TWAPs. Operation is operationalised by the Core Team which has a DAO mandate to buyback entirety of solver rewards emitted in the week, with a mandate to buy up to 120% solver rewards.
• Tokens bought back are held at the DAO's disposal for funding future solver rewards initiatives, creating a self funded flywheel, under governance approval.

(b) Protocol-owned liquidity (POL)

CoW Treasury committee keeps several POL positions which can be reviewed under https://dune.com/kpk/cow-token-analysis. All pools are owned by CoW Treasury address 0x616dE58c011F8736fa20c7Ae5352F7f6FB9F0669.

(c) Liquidity deals / purchased TVL

No TVL oriented deal exists.

(d) Token-secured loans/lines (incl. against unissued tokens)

No token-secured loans or lines, including against unissued COW, currently exist at the DAO level.

(a) Entity existence

• CoW DAO — Exists as an unincorporated, on-chain organization governed by COW token holders via Snapshot at cow.eth. Constitutional document: Participation Agreement (CIP-1).
• CoW Foundation — Exists. Cayman Islands Company Foundation; shareholder-less and member-less.
• CoW Core Limited — Exists. BVI Company Limited by Guarantee; sole member CoW Foundation.
• CoW Hosting Limited — Exists. BVI Company Limited by Guarantee; sole member CoW Foundation.
• CoW Business Limited — Exists. BVI Limited Liability Company / company limited by shares; sole shareholder CoW Foundation.

(b) Material sources of funding or economic inflows

CoW DAO (unincorporated):

• Unincorporated DAO does not generate or control flows. It is the ultimate owner of any economics flow or asset in the CoW Ecosystem. CoW Foundation:
• Receives profit generated from its subsidiary CoW Core.
• May generate treasury yield on assets under management.
• In turn allocates funding to all four entities via the auto-renewing operational budget (estimated $130k in 2025; $180k/year in following years for the entire structure; +/- 10% Director discretion). CoW Core Limited, CoW Hosting Limited:
• Funded by allocations from CoW Foundation. CoW Core may receive service fees for analytics or solver-related services where applicable. CoW Business Limited:
• Funded by allocations from CoW Foundation. Generates revenue from partner fee agreements (CIP-61) and commercial integrations; this revenue flows back to CoW Foundation as profit.
• Protocol fees collected at the settlement contract level. CoW DAO fees consist of:
• Price improvement fee: 50% of surplus on out-of-market limit orders, capped at 0.98% of total order volume.
• Volume-based fee: 2 basis points (0.02%) on non-correlated asset pairs (correlated pairs such as stablecoin↔stablecoin, ETH↔stETH/wstETH, token↔wrapped versions, and RWA↔stablecoin pairs are subject to a reduced fee of 0.3 basis points (0.003%))
• Service fees collected from solvers (netted against rewards) and partners on certain integrations under partner-specific CIPs (e.g., framework set by CIP-61).
• Yield generated by Karpatkey on idle treasury funds in the CoW Treasury safe.

(c) Operational use of resources

• DAO funds support: solver rewards (the largest recurring outflow, governed by CIP-20), the CoW Grants program, security audits, partner reward programs, and retained treasury for long-term operations.
• Foundation funds: ecosystem promotion, treasury management, grants administration, legal protection of the protocol and contributors (Defense Reserve per CIP-50), tooling/coordination across entities, community management.
• CoW Core funds: solver operations management, backend infrastructure (orderbook, autopilot, Reference Driver), solver R&D, analytics.
• CoW Hosting funds: UI hosting and maintenance (CoW Swap, CoW Widget), domain ownership, user support, token list management.
• CoW Business funds: solver reward calculation/distribution operations, COW buyback execution, partner relationship management, CEX listings, market maker relationships, fee-agreement negotiation.
• Service providers (Leeward Management, Leeward Supervisors, Lemma Solutions) are paid fee-for-service from the operational budget for corporate, legal, and operational services respectively.

(d) Onchain Resource Usage

public dashboards

Incident: DNS compromise

(a) Date & component affected

April 14, 2026. Registrar compromise leading to the takeover of cow.fi domain DNS settings, specifically affecting the swap.cow.fi frontend interface.

(b) Exploit vector summary

Attackers used social engineering and forged identity documents to compromise the .fi domain. The attack involved hijacking DNS resolution and redirecting users from swap.cow.fi to a malicious phishing site. The fake site deployed a forged transaction interface designed to trick users into connecting wallets and signing malicious transactions. Core infrastructure including on-chain contracts, backend systems, AWS, and Vercel remained uncompromised.

(c) Quantified impact

Approximately $1.2 million in user losses.

(d) Remediation/response taken

Team detected the anomaly and initiated emergency response within 19 minutes. CoW DAO paused backend and APIs as a precautionary measure and migrated operations to cow.finance temporarily and fully restored the original cow.fi domain within approximately 26 hours. Domain was recovered, restored to AWS account with a registry lock (RegistryLock) for enhanced security. The DAO voted on a governance proposal to make users whole and refunded the losses while further legal action is pursued with registrars.

(e) Current status

Resolved. Domain recovered and secured with registry lock. Users made whole via the CIP-86 discretionary grants program. Legal action against the registrar is ongoing.

(f) References

• https://x.com/CoWSwap/status/2044924940886163780
• https://forum.cow.fi/t/cip-86-discretionary-grants-program-for-victims-of-the-cow-fi-domain-hijacking/3431 Incident: Barter Solver / SwapGuard Exploit

(a) Date & component affected

2023-02-07. Component: the GPv2Settlement contract on Ethereum mainnet, via a malicious "SwapGuard" helper contract that the recently-onboarded "Barter" solver had granted a max-DAI approval to.

(b) Exploit vector summary

The Barter solver, which had been added to the solver allow-list on 2023-01-27, deployed a SwapGuard helper contract that exposed an arbitrary-call interface. Barter then granted max DAI approval from the GPv2Settlement contract to SwapGuard. An attacker, aware of how CoW Swap solvers operate, waited until the last day of the weekly fee-accrual period and used the public arbitrary-call function on SwapGuard to drain the approved DAI from the settlement contract.

(c) Quantified impact

~$166,000 in DAI was drained from the settlement contract, representing one week of accrued protocol fees. No user funds were affected. CoW Protocol does not custody user funds in transit — settlement is atomic — so user trades and approvals were not at risk.

(d) Remediation/response taken

CoW Swap revoked all approvals tied to the malicious contract and upgraded to a settlement helper that does not support arbitrary code execution. The protocol's solver bonding pool mechanism (introduced in CIP-7, requiring solvers to deposit $500,000 cUSDC and 1.5M COW as collateral) was used to recover losses — the Barter solver refunded the protocol from its bond on 2023-02-08, the day after the incident. A detailed post-mortem was published.

(e) Current status

Resolved. Funds recovered via solver bond. Protocol's bonding mechanism functioned as designed.

(f) References

• https://blog.cow.fi/cow-swap-solver-exploit-post-mortem-07-02-2023-2faa9f918e2 9
• https://forum.cow.fi (CIP-7 — solver bonding pool)

2025 (10 months) running cost: $130,000

• Following years' running cost: $180,000/year
• One-time setup cost: ~$50,000 (+/- 10%, borne by service provider under CIP-58)
• Estimated annual cost savings vs. prior unincorporated setup: ~$100,000 These are aggregate numbers across the entire 4-entity structure and not a substitute for an entity-level income statement, but they provide context.