Tokenization of assets, from bonds and funds to real estate, is heralded as the next evolution in finance. Yet, turning this vision into reality requires more than technology; it demands clear regulation. 

In this article, we evaluate the top 6 jurisdictions leading the charge in regulated tokenized real world assets space. We’ll explain why regulatory frameworks are essential, highlight how different countries are approaching tokenization, and compare key markets with respect to clarity of rules, licensing structures, live projects, and market activity. 

The goal is to provide financial institutions, asset managers, and fund executives a comprehensive guide to choosing the right jurisdiction for their tokenization initiatives.

Why Regulation is Essential for Tokenized Assets

Tokenized real world assets (RWAs) are digital representations of traditional financial instruments. Since these assets often qualify as securities, they require a clear regulatory framework to ensure compliance and protect investors. Regulatory certainty fosters market confidence, reduces operational risk, and enables global interoperability. 

Adapting Existing Laws vs. New Digital Asset Frameworks

The tokenization industry is still in its early stages, and the regulatory landscape is continually evolving. Some jurisdictions apply existing securities laws to digital assets, while others are creating entirely new frameworks. Many countries are still grappling with the implications of tokenization, and some have chosen to adopt a cautious approach, fearing potential risks to financial stability. However, others are embracing tokenization as a way to modernize financial markets and attract global capital.

As a result, we see a wide variation in regulatory approaches, from strict regulatory control to regulatory sandboxes, where firms can experiment with tokenized asset offerings in a controlled environment. 

Top Active Jurisdictions for Tokenization

Here’s a detailed, objective assessment of the leading jurisdictions for tokenized assets and security token offerings (STOs).

Singapore: A Regulated Tokenization Pioneer

The Monetary Authority of Singapore (MAS) regulates tokenized RWAs under the Securities and Futures Act, treating them as securities since they exhibit traditional characteristics (e.g. representing equity, debt, or investment units). In practice, this means security tokens in Singapore fall under the Securities and Futures Act and related regulations.

MAS also licenses tokenization platforms  which touch upon capital markets products under the existing Capital Markets Services (CMS) and Recognized Market Operator (RMO) frameworks. For example, InvestaX is licensed by MAS as a CMS provider (for dealing in securities) and as a RMO for secondary trading – essentially the same licenses a conventional securities exchange or broker would need. 

Notable Initiatives: 

• MAS’s Project Guardian: Since 2022, MAS has partnered with 24 financial institutions to pilot tokenized bonds, deposits, and funds in its regulatory sandbox. In 2024, MAS announced plans to commercialize asset tokenization, transitioning from sandbox trials to full adoption.
• Project e-VCC: a proof-of-concept co-led by InvestaX, UBS, State Street, and PwC, with MAS support. Project e-VCC pioneered the blockchain-native eVCC fund structure, enabling direct issuance and secondary trading of tokenized fund shares.

Notable Market Activity: 

• UBS’s Tokenized USD MMF: UBS launches its “UBS USD Money Market Investment Fund Token” (“uMINT”), built on Ethereum distributed ledger technology, targeting accredited investors (Ledger Insights, 2024).
• StanChart’s Tokenized U.S. Treasury Fund:  Standard Chartered, in collaboration with LIBEARA, has launched the tokenized "Wellington U.S. Treasury Fund" in Singapore, allowing institutional investors to gain exposure to U.S. Treasury securities (Ledger Insights, 2024).

Business Considerations

• Singapore’s regulatory regime is clear but evolving. While current laws such as the Variable Capital Company Act permit blockchain-native securities, targeted amendments could further enhance legal certainty, especially around book-entry securities and digital registers.
• The city-state offers a mature ecosystem for institutional-grade offerings, with end-to-end licensed platforms like InvestaX providing issuance, custody, and secondary trading.
• Tax and stamp duty implications exist but are being managed with ongoing dialogue between industry and regulators to streamline digital asset transactions.

Best For

• Singapore is an ideal choice for institutions seeking regulatory clarity, robust infrastructure, and a strategic gateway to both Asian and global investors.

United Arab Emirates (UAE): Proactive Innovation in the Sandbox 

The UAE has rapidly positioned itself as a crypto-friendly yet regulated environment for digital assets, including security tokens, with its Virtual Asset Regulatory Authority (VARA) and regulatory efforts in the Dubai International Financial Centre (DIFC). VARA focuses on creating a legal framework for digital assets, which includes tokenized securities. 

Notable Initiatives: 

• Dubai Land Department Real Estate Tokenization Pilot: In early 2025, the UAE launched a Real Estate Tokenization Pilot through the Dubai Land Department (DLD), tokenizing property title deeds on blockchain (Middle East Briefing, 2025). 
• Digital Asset Oasis in ADGM and DIFC: The UAE has developed the Digital Asset Oasis in ADGM and DIFC, fostering a hub for blockchain firms. In 2024, DIFC introduced new laws and amendments to accommodate digital asset activities, with VARA providing compliance guidelines for tokenized offerings (DIFC, 2024).

Notable Market Activity:

• Landmark $3B real estate tokenization involving MAG, MultiBank, and MAVryk, demonstrating the region’s appetite for large-scale tokenized deals.

Business Considerations

• The UAE is innovation-friendly and offers regulatory sandboxes for pilots.
• Legal enforceability and cross-border recognition are still maturing; due diligence on local licensing and operational requirements is crucial.

Best For

• Real estate tokenization.
• Projects targeting Middle East investors and seeking regulatory flexibility.

Hong Kong: Integrating Tokenization into Traditional Finance

Hong Kong’s Securities and Futures Commission (SFC) regulates tokenized securities under existing securities law - the Securities and Futures Ordinance. The city-state has also introduced a tokenized green bond framework and recently indicated support for security token offerings (STOs) under a sandbox regime.

Notable Market Activity:

• Hong Kong’s Digital Green Bond (2023, 2024): The Hong Kong Special Administrative Region (HKSAR) Government issued its first tokenized green bond in February 2023, denominated in HKD and valued at approximately US$100 million, marking the world's first tokenised government green bond. The second issuance of Hong Kong's digital green bond worth HK$6 billion happened in February 2024 (ICMA, 2024). 
• Hong Kong Green-Lights Tokenized Securities: Guotai Junan International, the Hong Kong arm of one of China’s largest brokerages, recently received informal clearance from the SFC to issue tokenized securities, suggesting a more open environment for tokenized offerings. (Ledger Insights, 2025). 

Business Considerations

• Hong Kong offers access to Chinese and pan-Asian capital, but market participants should monitor regulatory updates as the landscape continues to evolve.

Best For  

• Hong Kong is best suited for issuers targeting capital from mainland China. It combines a common law-based legal system with a renewed government focus on fintech, making it a strong gateway for accessing the broader North Asia market.

Switzerland: Legal Certainty and Financial Infrastructure for Tokenization

Switzerland’s DLT Act recognizes tokenized securities as legally enforceable. FINMA provides oversight for tokenized securities, making Switzerland one of the most established jurisdictions for blockchain finance.

Notable Market Activity: 

• Societe Generale’s €100 million tokenized bond issuance on the SDX platform is a notable example (Societe Generale, 2019).

Business Considerations

• Switzerland’s framework is mature, but operational requirements (e.g., registration agreements for ledger-based securities) require careful structuring.
• The jurisdiction is well-suited for institutional offerings and projects prioritizing legal certainty.

Best For

• Firms seeking legal certainty in the EU and wider European market, with strong institutional and regulatory backing for highly regulated, institutional-grade tokenization projects.

European Union (EU): Bridging Traditional Securities Law and New Crypto Rules

The EU’s regulatory framework for tokenized assets is primarily governed by MiFID II for tokenized securities and MiCA for non-security tokens such as cryptocurrencies. Some member states, like Luxembourg and Germany, have enacted specific DLT laws to enable blockchain-native securities.

Recent Initiatives:

• The flagship EU initiative for tokenized markets is the DLT Pilot Regime, which came into effect in March 2023. This is an EU-wide regulatory sandbox that allows approved market infrastructure operators to experiment with trading and settling tokenized financial instruments under a lighter regulatory regime (with temporary exemptions from some requirements of MiFID, CSDR, etc.). 

Business Considerations

• The EU offers passporting for pan-European offerings, but regulatory fragmentation exists between member states.

Best For

• Pan-European distribution.
• Issuers seeking access to EU institutional and retail investors.

United States: Innovation Amid Regulatory Uncertainty

The United States is a paradox in the tokenization space – it is home to many of the largest financial institutions exploring tokenization, such as Blackrock and Franklin Templeton, yet its regulatory environment for digital assets has been among the most challenging to navigate. In the U.S., tokenized assets that constitute “securities” fall under the purview of the Securities and Exchange Commission (SEC) and must comply with the Securities Act of 1933 and Securities Exchange Act of 1934. Unlike jurisdictions that wrote new laws or safe harbors, the SEC has largely treated crypto and security tokens under its existing framework. 

Recently, the SEC has shown signs of softening its stance: 

• Tokenization Roundtable: The SEC’s Crypto Assets and Cyber Unit held a special tokenization roundtable in May 2025. This roundtable, part of a series on crypto regulation, brought together SEC Commissioners and industry experts to debate how tokenization of traditional assets can improve market efficiency and how regulations might adapt (SEC, 2025).
• SEC Proposes Exemption For Tokenization, DLT Securities: The U.S. Securities and Exchange Commission (SEC) is considering an exemption order that would allow firms to use distributed ledger technology (DLT) to issue, trade, and settle securities. This move aims to modernize securities regulations and accommodate technological advancements (Ledger Insights, 2025).
• U.S. Regulators Give Banks the Green Light for Digital Asset Activities: Federal banking regulators, including the Federal Deposit Insurance Corporation (FDIC), Federal Reserve, and Office of the Comptroller of the Currency (OCC), have rescinded previous restrictive statements on crypto assets. This change permits banks to explore services like custody, payments, tokenization, and blockchain infrastructure (Chainalysis, 2025). 

Business Considerations

• U.S. market access is significant, but legal and compliance costs are high.
• Compliance with state-specific Blue Sky laws 
• State-level innovation (e.g., Delaware, Wyoming) offers additional structuring options.

Best For

• Projects with U.S. investor focus, looking to tap into a vast, capital-rich market.

Conclusion: Aligning Jurisdiction with Strategy

Each jurisdiction offers unique opportunities for issuers of tokenized assets, depending on their regulatory priorities and target markets. While countries like Singapore, Switzerland, and the EU provide clear legal frameworks for tokenized assets, emerging markets like the UAE and Hong Kong offer innovation-friendly environments with rapid regulatory support. The U.S. represents a massive market with evolving regulations, presenting opportunities and challenges for issuers.

For financial institutions, asset managers, and fund executives considering tokenization, the choice of jurisdiction should be guided by your business goals and your investors’ profile:

• If your priority is legal certainty and institutional trust: Jurisdictions like Switzerland or Singapore might be ideal. These offer well-established regulations and a track record of successful tokenized offerings. You may trade a bit of speed or retail flexibility in exchange for this certainty, but you gain credibility by aligning with top-tier regulatory standards.
• If you seek innovation and faster go-to-market: UAE (Dubai/ADGM) and Hong Kong could be attractive. They have regulators explicitly encouraging tokenization through new laws, sandboxes, and even funding incentives. These are great for projects like tokenized real estate or funds targeting professional investors who are open to new markets. Just be prepared to work within multi-layered regulatory environments (especially UAE, with its multiple jurisdictions).
• If you need broad market access, including retail investors in major economies: Consider the EU, which through passporting can give pan-European reach, or plan a multi-jurisdiction strategy (e.g., Singapore for Asia + EU for Europe). Hong Kong is also opening to retail in 2024, which could be a game-changer for tapping wealth in Asia under regulated conditions.
• If your project is U.S.-linked or you want U.S. investor participation: While working within SEC exemptions (Reg D/S) and using U.S.-compliant platforms might be cumbersome, nevertheless as shown by BlackRock’s BUIDL and Hamilton Lane’s tokens, it can be done successfully. For U.S. distribution, a solid legal team and possibly engaging with regulators (through no-action letter requests or sandbox-like arrangements) is key. The tide in the U.S. may turn towards clearer rules, and early movers will be well-positioned to benefit.

Across all jurisdictions, one takeaway is that compliance and investor protection must remain front and center. Tokenization doesn’t erase those responsibilities; it shifts how they’re implemented. Platforms like InvestaX – which is licensed and regulated by the MAS provides a secure and regulated infrastructure for both issuers and investors, enabling seamless participation in the growing tokenized asset space.

‍