Navigating the Compliance Maze: Global Regulations Shaping Tokenized Real Assets
As the tokenization of real world assets (RWAs) gains momentum, compliance has become the critical path between innovation and adoption. From securities laws to tax codes, every jurisdiction takes its own approach to regulating tokenized assets, making it challenging for issuers, investors, and platforms to operate across borders.
At Molokai Group, we believe understanding this regulatory landscape is key to unlocking the next phase of growth for RWAs. This blog compares the evolving frameworks in the United States, Singapore, and the United Kingdom—three of the world’s leading financial centers.
Accreditation standards: who qualifies as an RWA investor?
One of the first regulatory hurdles in RWA issuance is defining who can participate. Regulators have set varying accreditation thresholds to balance investor protection with access.
In the United States, the Securities and Exchange Commission (SEC) defines an accredited investor as someone with net assets exceeding $1 million (excluding primary residence) or annual income above $200,000 ($300,000 joint) over the last two years. This threshold ensures that tokenized securities can only be sold to investors who meet established wealth criteria under Reg D exemptions (FT Wealth, 2024 [5]).
Singapore’s Monetary Authority of Singapore (MAS) sets its accredited investor bar at S$2 million in net personal assets, excluding primary residence, or S$1 million in financial assets. This aligns with Singapore’s broader goals of growing its private wealth management hub while ensuring a sophisticated investor base (DBS, 2024 [1]).
The United Kingdom’s Financial Conduct Authority (FCA) applies a lower threshold for high net worth individuals, recognizing those with £250,000 in net assets, excluding primary residence, pensions, or insurance. Investors must also self-certify to access certain tokenized securities or private offerings.
For issuers of tokenized real estate, private equity, or debt, these varying standards require careful investor onboarding processes, with identity and accreditation verification tailored to each jurisdiction.
Anti-fraud measures: integrating blockchain analytics into compliance
As regulators look to prevent money laundering and fraudulent schemes within tokenized asset markets, compliance teams are adopting blockchain analytics solutions as a critical safeguard.
Leading platforms now integrate tools like Chainalysis into their transaction monitoring pipelines, enabling real-time detection of suspicious wallet interactions, flagged addresses, and anomalous trading patterns (FT Wealth, 2024 [5]). This step is especially important for cross-border RWA trades, where proceeds may flow through multiple jurisdictions before settlement.
For Molokai Group, leveraging blockchain analytics is not only about compliance—it’s about building investor trust. We believe that verifiable, auditable transaction histories will be a cornerstone of institutional adoption of tokenized RWAs.
Tax innovations: navigating incentives and exposures
Beyond securities regulation, tax treatment plays a defining role in the attractiveness of tokenized real assets across markets.
Portugal has emerged as an early mover, introducing a “tax holiday” on gains from tokenized real estate and other digital securities under specific conditions. This policy has attracted digital nomads and crypto entrepreneurs looking to deploy capital into blockchain-based real estate investments with minimal tax friction.
In contrast, the United States recently updated its treatment of tokenized property under Foreign Investment in Real Property Tax Act (FIRPTA) guidelines. Under revised interpretations, foreign investors in tokenized US real estate may still be subject to FIRPTA withholding, underscoring the need for robust tax planning.
The United Kingdom takes a more traditional approach, applying capital gains tax rules to tokenized assets much like physical property or securities, with no specific carveouts for blockchain-based formats.
Investors moving capital across borders must weigh these tax regimes carefully, especially as governments reevaluate crypto-related tax codes in 2025.
The global compliance challenge: Molokai Group’s role
The fragmented nature of tokenized asset regulation can feel overwhelming, but it also presents opportunities for those with the right knowledge and access. Understanding where and how to invest legally, efficiently, and globally is what separates early adopters from long-term winners.
At Molokai Group, we give our members the insights, access, and strategic clarity they need to make the most of this evolving space.
Join the Molokai Membership to gain access to rare, tax-free investment opportunities, exclusive content, and a one-on-one session with our expert team to help you get started.
References
DBS (2024). DBS Expands Crypto Services to Mass Affluent Segment.
FT Wealth (2024). Crypto Demand from Wealthy Clients.
