RWA Terminal

European Union · ESMA / European Commission

MiCA (Markets in Crypto-Assets Regulation)

MiCA entered into full application on 30 December 2024, establishing a comprehensive EU-wide licensing regime for crypto-asset service providers and issuers of asset-referenced tokens and e-money tokens.

United Kingdom · FCA

Cryptoasset Regulation (FSMA 2023)

The Financial Services and Markets Act 2023 brought cryptoassets within the UK regulatory perimeter. The FCA is developing a comprehensive regime for cryptoasset activities, with consultation papers published in 2024 covering admissions and disclosures, market abuse, and trading platforms.

United Kingdom · FCA / Bank of England

Digital Securities Sandbox

The UK Digital Securities Sandbox (DSS), launched in 2024 under the Financial Services and Markets Act 2023, allows firms to issue, trade and settle tokenized securities under a modified regulatory framework, with the FCA and Bank of England as joint regulators.

Hong Kong · HKMA

Project Ensemble

HKMA Project Ensemble is a wholesale CBDC and tokenization sandbox exploring interoperability between tokenized money and tokenized real-world assets. Phase 1 focused on tokenized deposits and green bonds; Phase 2 expanded to trade finance and carbon credits.

United States · SEC

Securities Law Application to Tokenized Assets

The SEC has confirmed that tokenized securities remain subject to existing federal securities laws. The Commission has issued guidance and taken enforcement actions establishing that most tokenized financial instruments constitute securities under the Howey test.

Singapore · MAS

Project Guardian

MAS Project Guardian is an industry collaboration exploring asset tokenization across fixed income, foreign exchange and asset management. Phase 2 expanded to include tokenized fund structures and cross-border settlement with multiple global financial institutions.

Singapore · MAS

Payment Services Act (Digital Payment Tokens)

The amended Payment Services Act regulates digital payment token services in Singapore. MAS has issued licensing requirements for digital token service providers and published guidelines on custody of digital assets.

UAE — Dubai · VARA

Real Asset Token Regulations

VARA published dedicated Real Asset Token (RAT) regulations establishing requirements for the issuance and trading of tokens backed by real-world assets, including real estate and commodities.

European Union · European Investment Bank / ESMA

Tokenized Bond Issuances

The European Investment Bank has issued multiple digital bonds on public blockchains under the DLT Pilot Regime framework, establishing precedent for institutional tokenized debt securities in the EU.

United States · CFTC

Digital Asset Derivatives Oversight

The CFTC maintains jurisdiction over digital asset derivatives and has published guidance on the application of commodity exchange regulations to tokenized commodity products and related derivatives.

Switzerland · FINMA

Tokenized Securities Guidance

FINMA has published guidance on the regulatory treatment of tokenized securities and collective investment schemes, clarifying that tokenized shares, bonds and fund units are subject to existing financial market law.

UAE — Abu Dhabi · ADGM / FSRA

Digital Securities Framework

The ADGM Financial Services Regulatory Authority operates a comprehensive digital securities framework permitting the issuance, trading and settlement of tokenized securities within the Abu Dhabi Global Market free zone.

UAE — Dubai · VARA

Virtual Assets Regulatory Authority Framework

VARA issued its comprehensive Virtual Asset Service Provider (VASP) regulations in 2023, covering licensing, market conduct, and compliance requirements for virtual asset activities in Dubai, including tokenized real-world assets.

Hong Kong · SFC

VASP Licensing Regime

The SFC mandatory licensing regime for virtual asset trading platforms came into effect on 1 June 2023. The SFC has published circulars on tokenized securities and the regulatory treatment of tokenized investment products.

European Union · ESMA

EU DLT Pilot Regime

The DLT Pilot Regime (Regulation EU 2022/858) has been operational since 23 March 2023, allowing market infrastructures to operate DLT-based multilateral trading facilities and settlement systems for tokenized financial instruments under a temporary exemption framework.

South Korea · Financial Services Commission

Security Token Roadmap

The FSC published a security token issuance and distribution roadmap in 2023, establishing a framework for tokenized securities under existing capital markets law. Pilot issuances of tokenized bonds and real estate investment trusts have been approved.

Switzerland · FINMA

DLT Financial Market Infrastructure Act

Switzerland enacted the DLT Act (Federal Act on the Adaptation of Federal Law to Developments in Distributed Ledger Technology) in 2021, creating a new category of DLT trading facility and enabling the issuance of ledger-based securities (Registerwertrechte).

Japan · Financial Services Agency

Security Token Offering Framework

Japan amended the Financial Instruments and Exchange Act to regulate security token offerings (STOs). Tokenized bonds and equity instruments are classified as electronically recorded transferable rights and subject to disclosure and registration requirements.