SCHEDULE: Tether Entities Boost Bitdeer Stake to 18.2%

Tether Holdings and its affiliates have increased their beneficial ownership in Bitdeer Technologies Group to 18.2% through recent open market purchases.

Summary

• Tether Holdings, S.A. de C.V., Tether Investments, S.A. de C.V., and Giancarlo Devasini (collectively, "Reporting Persons") beneficially own an aggregate of 32,244,062 Class A ordinary shares of Bitdeer Technologies Group.
• This ownership represents 18.2% of the outstanding Class A Shares of Bitdeer Technologies Group.
• The percentage is calculated based on 177,344,567 Class A Shares outstanding as of September 30, 2025, as reported in the Issuer's prospectus supplement filed on November 14, 2025.
• Tether Investments S.A. de C.V. completed open market purchases of Class A Shares between November 17, 2025, and November 21, 2025.
• Individual purchase prices for these transactions ranged from $9.6994 to $10.1500 per share.
• This document is Amendment No. 10 to the original Schedule 13D filed on June 6, 2024.

Sentiment

Score: 6

Explanation: The increased stake by Tether indicates confidence in Bitdeer, which is positive. However, the historical regulatory issues of Tether itself introduce a degree of caution.

Positives

• Continued investment by a significant entity (Tether) in Bitdeer Technologies Group, indicating confidence in the company's prospects.
• Increased beneficial ownership to 18.2% suggests a growing strategic interest and commitment from the Reporting Persons.

Negatives

• The reporting entity, Tether, has a history of significant regulatory penalties, including a $41 million civil monetary penalty from the CFTC in October 2021 and $18.5 million in penalties to the State of New York in February 2021, related to misrepresentations about USDT backing and trading activities.

Risks

• Past regulatory actions against Tether (CFTC and NYAG) for misstatements and omissions regarding USDT backing and trading activities could pose reputational or operational risks to the Reporting Persons, which might indirectly affect their investment in Bitdeer.
• The Reporting Persons' involvement in the volatile cryptocurrency industry may introduce additional market and regulatory risks to their investment in Bitdeer.

Future Outlook

The filing does not provide specific forward-looking statements or guidance from Bitdeer Technologies Group. It primarily details the current ownership stake and recent transactions of the Reporting Persons.

Management Comments

• Mr. Devasini has a greater than 50% voting interest in Tether Holdings, S.A. de C.V.
• The reporting person disclaims beneficial ownership of these shares except to the extent of the reporting person's pecuniary interest.

Industry Context

This filing highlights continued institutional interest from major cryptocurrency entities like Tether in the Bitcoin mining sector, represented by Bitdeer Technologies Group. Tether's increased stake suggests a strategic alignment or belief in the long-term value of Bitcoin mining operations, despite the inherent volatility and regulatory scrutiny often associated with the broader crypto industry.

Comparison to Industry Standards

• This filing is a Schedule 13D/A, which primarily discloses beneficial ownership changes rather than operational or financial results. Therefore, a direct comparison to industry operational or financial benchmarks is not applicable. The significance lies in the increased stake by a prominent entity in the cryptocurrency space, Tether, in a publicly traded Bitcoin mining company, Bitdeer Technologies Group.

Legal Proceedings

• In October 2021, the U.S. Commodity Futures Trading Commission (CFTC) instituted and settled regulatory proceedings against Tether Holdings Limited, Tether Limited, Tether Operations Limited, and Tether International Limited, resulting in a civil monetary penalty of $41 million for making untrue or misleading statements regarding USDT backing.
• In February 2021, the Office of the Attorney General of the State of New York (NYAG) entered into an agreement with Tether and several Bitfinex companies, settling a 2019 proceeding with $18.5 million in penalties and requiring discontinuation of trading activity with New York persons/entities and mandatory reporting on certain business functions.

Stakeholder Impact

• Shareholders (Bitdeer): Increased institutional ownership by a major crypto entity could be seen as a vote of confidence, potentially stabilizing or boosting share price.
• Shareholders (Tether): The investment represents a deployment of capital into a strategic asset within the crypto ecosystem.
• Regulatory Bodies: The filing provides transparency regarding significant ownership stakes, consistent with SEC disclosure requirements.

Next Steps

• The filing does not explicitly state future actions or milestones for Bitdeer Technologies Group or the Reporting Persons beyond the ongoing disclosure requirements of Schedule 13D.

Key Dates

Recommendation

The increased stake by Tether in Bitdeer Technologies Group signals continued confidence from a major player in the crypto ecosystem, which is a positive indicator for Bitdeer. However, the historical regulatory issues faced by Tether itself introduce a layer of risk and uncertainty. While the investment is a bullish sign for Bitdeer, the broader market volatility in the crypto sector and the reporting entity's past compliance challenges suggest a 'hold' position is prudent, awaiting further operational or financial developments from Bitdeer and clearer resolution of any potential indirect impacts from Tether's regulatory environment.

Keywords

Bitdeer Technologies Group, Tether Holdings, Tether Investments, Giancarlo Devasini, Schedule 13D/A, Class A Shares, Beneficial Ownership, Cryptocurrency, Bitcoin Mining, SEC Filing, Institutional Investment