Authors: Li Zhongzhen, Song Zeting
What is RWA?
RWA (Real World Assets) refers to converting physical assets from the real world (such as real estate, gold, artwork, etc.) or property rights (such as debt rights, revenue rights, fund shares, etc.) into digital tokens that can circulate on the blockchain. It is an innovative model that achieves asset fragmentation, open ledgers, free circulation, and automated management. Its technical foundation relies on the blockchain's immutability and smart contracts' automatic execution capabilities, and requires legal confirmation to ensure the consistency of on-chain rights and underlying asset ownership. In simple terms, RWA is very similar to asset securitization in traditional finance, but more innovative and flexible.
[The rest of the translation follows the same professional and accurate approach, maintaining the technical terminology and context of the original text.]Since most RWA tokens may be considered securities tokens, they must be securitized, which means these RWA tokens must comply with the securities regulatory policies of their circulation area. Otherwise, if deemed non-compliant, they may face massive fines or even criminal risks. Global Regulatory Landscape for RWA Tokens Currently, there are no specific regulatory policies for RWA tokens. As RWA tokens are essentially crypto assets, their regulation still applies to the crypto asset policies and regulations of various regions. (I) Hong Kong Hong Kong's regulatory draft for RWA stablecoins was officially passed on May 21, 2025, discussing the compliance framework and regulatory possibilities through 8 key points: 1. Licensing system and entry thresholds 2. Reserve asset requirements 3. Transparency and information disclosure 4. Anti-money laundering and counter-terrorism financing 5. Legal enforcement rights of regulatory authorities 6. Cross-border coordination and enforcement 7. Investor protection mechanisms 8. Technological advancement and sustainable regulation [The rest of the translation follows the same professional and accurate approach, maintaining the original meaning while translating into clear English.](III) Singapore
On January 14, 2019, Singapore passed the Payment Services Act (PSA) and continuously revised it as a "forward-looking and flexible framework for regulating payment systems and service providers". This act replaced the previous Payment Systems Supervision Act and Currency Exchange and Remittance Businesses Act. Additionally, The Monetary Authority of Singapore (MAS) issued Notification PSN01 under the PSA (Prevention of Money Launand Terrorism and terrorism Financing - Designated Payment Services), introducing Anti-Money Laundering (AML) and Countering the Financing of Terrorism (CFT) requirements for regulated payment service providers. This means payment service providers must implement the measures to achieve achieve regulatory compliance:
Risk assessment and mitigation>
Customer due due didiligence
Reliance on third parties
Agent accounts and wire transfers
Record keeping
Suspicious transaction reporting
Internal policies, compliance, audit and training
On March 27, 2025, the Monetary Authority of Singapore issued the "Paper on the Prudential Treatment of Cryptoasset Exposures and Requirements for Additional Tier 1 and Tier 2 Capital Instruments for Banks", aiming to implement the updated prudential treatment and disclosure standards for cryptoasset risks by the Basel Committee on Banking Supervision (BCBS). It mentioned that cryptoassets passing all classification conditions are categorized as Group 1a cryptoassets (tokenized versions of traditional assets) or Group 1b cryptoassets (cryptoassets designed to exchange pegged value, with a predpredefined reference asset or asset value and an effective stabilization mechanism).
For cryptoassets classified as Group 1b, BCBS prescribed a redemption risk test for cryptoasset, at assets are sufficient to redeem the pegged value at any time. To pass the redemption risk test, banks must ensure the reserve assets of cryptoassets meet conditions related to the value, composition, and management of reserve assets.
(IV) European Union
In June 2023, the European Union officially released the Markets in Crypto-Assets Regulation (Mii), two categories of regulatory targets:
1) The first cryptoasset isis, including stcoinissuanders other cryptoassetissuers.
MiCA has the following main requirements forStablecoin issuers:
Obtain authorization before issuance
Fulfill disclosure obligations
Hold a certain scale of own funds and reserve assets
MiCA has relatively relaxed requirements for other cryptoasset issuers:
Issuers must establish a legal entity within the EU
Publish a whitepaper
2) The second category of regulatory targets is cryptoasset service providers. MiCA's requirements for cryptoasset service providers mainly include four aspects:
Obtain authorization
Improve governance structure
Minimum capital requirements
Consumer protection and transparency requirements
