CLSK · CIK 827876
What CleanSpark, Inc. told the SEC could break it.
CleanSpark's economics run entirely on bitcoin: its roughly $766 million in FY2025 mining revenue is set by how many bitcoins it mines and the price on the day it mines them, and because it holds about 98% of its bitcoin in cold storage, the value of its treasury swings with the same price. The hardware that drives all of it — ASIC miners — comes from a limited number of suppliers heavily concentrated in China-linked manufacturers (Bitmain, MicroBT, Canaan), with supply chains running through China, Malaysia, Indonesia and Thailand, creating availability risk for the equipment its hashrate depends on. That China exposure has already turned concrete: starting in May 2025, U.S. Customs began asserting Chinese-origin tariffs on miners it imported in 2024, a contested action it says could create a material contingent tariff liability it intends to fight.
3 self-disclosed vulnerabilities, pulled from its own filings, each in the company’s words, with the source. This is the risk register almost nobody reads.
In its own words
What could break it.
Commodity & input dependence
- Revenue entirely driven by Bitcoin price × bitcoins mined (~$766M FY2025 mining revenue)medium
CleanSpark's mining revenue — approximately $766 million in FY2025 — is determined by two main drivers: the quantity of bitcoin mined and the price of bitcoin on the date it is mined. In FY2025 it mined 7,873 bitcoins at an average price of $97,337 (vs. 7,092 at $53,434 in FY2024), and it holds ~98% of its bitcoin in cold storage, leaving it exposed to crypto-price swings between mining and sale. With revenue and the value of its bitcoin treasury both leveraged directly to the bitcoin price, and operations being highly power-intensive, the company is acutely exposed to the bitcoin commodity cycle, network difficulty and energy costs.
“are determined by two main drivers: quantity of bitcoin mined and the price of bitcoin on the date the bitcoin is mined.”
Regulatory & policy
- Realized CBP action asserting Chinese-origin import tariffs on miners — worst-case liability up to ~$185 million (contested)medium
CleanSpark imports its ASIC miners and is exposed to tariff and customs risk. On or about May 27, 2025 it began receiving invoices from U.S. Customs and Border Protection (CBP) asserting Chinese-origin import tariffs on certain miners imported from April through June 2024, despite documentation and seller representations that the hardware was not of Chinese origin. The company states that if CBP successfully asserts Chinese origin on all imported miners from April 2024 forward, its total tariff liability on previously purchased miners could rise to approximately $185 million (stated as $185,000 under the filing's thousands convention), excluding statutory interest — a potentially material contingent liability it intends to contest as without merit. Because its ASIC supply chains run through China, Malaysia, Indonesia and Thailand, trade restrictions, tariffs and CBP detentions remain an ongoing risk to importing the equipment its operations depend on.
“On or about May 27, 2025, the Company began receiving invoices from the U.S. Customs and Border Protection agency (“CBP”) asserting Chinese origin import tariffs on certain miners imported from April 2024 through June 2024.”
Supplier concentration
- Limited, China-dependent ASIC miner suppliers (Bitmain, Canaan, MicroBT); past import detentionsmedium
CleanSpark relies on a limited number of suppliers for the purchase and delivery of the ASIC miners that are essential to its bitcoin mining operations, and the global supply of miners is heavily dependent on manufacturers headquartered in China (Bitmain, MicroBT) with manufacturing across Asia (also Canaan). It has faced — and may again face — complications importing miners, including CBP detentions/seizures and origin disputes. Concentration in a few China-linked manufacturers, combined with long lead times and geopolitical/trade friction, creates supply-availability risk for the hardware its hashrate growth depends on.
“We rely on a limited number of suppliers for the purchase and delivery of our miners to support our bitcoin mining operations.”
The hidden graph
Who it depends on, and who depends on it.
Relationships surfaced from filings, including ones disclosed by the other side, which is how the non-obvious ones come to light.
Its customers
Foundry (Foundry Digital)
“During the fiscal year ended September 30, 2025, we mined 7,873 bitcoins, gross of Foundry fees, with an average bitcoin price of $97,337 as compared to 7,092 bitcoins with an average bitcoin price of $53,434 during the year ended September 30, 2024”
Cited →
Its suppliers
MicroBT
“We currently utilize several types of ASIC miners as part of our mining operation, including Bitmain Antminers, Canaan Avalon miners and MicroBT WhatsMiners, with supply chains in China, Malaysia, Indonesia or Thailand.”
Cited →Bitmain
“We currently utilize several types of ASIC miners as part of our mining operation, including Bitmain Antminers, Canaan Avalon miners and MicroBT WhatsMiners, with supply chains in China, Malaysia, Indonesia or Thailand.”
Cited →
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