Jurisdictions

The regulatory route, market by market.

Where our clients issue tokenised assets today, who regulates each market and how an issuance is usually structured. Every mandate is confirmed with counsel.

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General information, not legal advice. Subject to counsel review. Routes depend on the asset, the investors and the offering, and are confirmed for each mandate.

UAE · Abu Dhabi Global Market

A common-law centre with an established digital securities regime.

Tokenised securities and fund units are regulated by what they represent, so the usual securities and fund rules apply. The issuer or fund sits in ADGM, with FSRA-authorised firms for custody, dealing and any trading venue.

Fund or SPV established in ADGM
Offers typically to professional investors
FSRA-authorised custodian and secondary venue
We provide the platform as a technology provider

UAE · Dubai International Financial Centre

Tokenised investments treated like the investments they represent.

The DFSA regulates tokens that represent securities or fund units as investment tokens, under the same rules as the underlying investment. The DIFC Digital Assets Law recognises digital assets as property.

Fund, SPV or issuer established in DIFC
Offer, custody and trading each authorised separately
Strong fit for fund managers already in DIFC
Common-law courts and English-language regime

UAE · Dubai (outside DIFC)

Asset-referenced tokens under the VARA rulebooks.

In Dubai outside the DIFC, VARA regulates virtual assets, including asset-referenced tokens backed by real assets. Issuance needs VARA approval, and distribution and trading run through VARA-licensed service providers.

Issuer approval under VARA issuance rules
Distribution and trading through licensed VASPs
Suited to real estate and commodity-backed assets
Federal securities rules may apply to some structures

India · GIFT City (IFSC)

Fund structures today, with tokenisation moving through the sandbox.

IFSCA regulates GIFT City. Tokenised issuance and platforms currently run under the IFSCA FinTech sandbox while a final tokenisation framework is developed. Funds can use the existing fund management regime with tokenisation as the record-keeping layer.

Fund route through an IFSCA-registered fund manager
Issuance and platforms under sandbox authorisation
Technology providers register under the TechFin regime
Access to international and non-resident investors

Saudi Arabia

Securities rules first, with tokenisation through the CMA FinTech pathway.

The Capital Market Authority regulates securities offerings in the Kingdom. Tokenised offerings onshore currently run through CMA FinTech experimental permits. Alternatively, the asset can be structured in a UAE financial centre and offered to Saudi investors within Saudi offering rules.

Onshore route via a CMA FinTech experimental permit
Offshore route via ADGM or DIFC structures
Sukuk and real estate are the most active asset classes
Shariah review where the structure requires it

Somewhere else?

Your asset sits in another market.