Cross-Border Recognition of Tokenized Real-World Assets

Luxembourg) directly plus three EEA-anchored members (

Liechtenstein, and the EU members

Ireland). Every other jurisdiction pair requires parallel compliance. The four offshore and fund-domicile venues added in this refresh sit at opposite ends of the passporting spectrum:

Ireland is a full EU passporting member, while the

Cayman Islands, the British Virgin Islands, and Abu Dhabi's ADGM are third countries with no passport, relying instead on national private-placement regimes, IOSCO cooperation, and substance-based local classification.

Model A: Passporting

Passporting allows a firm authorized in one jurisdiction to provide services across all member jurisdictions of an economic bloc without obtaining separate licenses. The authorization of the home state is recognized by all host states within the bloc.

The

EU operates the most developed passporting regime for tokenized assets through two parallel frameworks:

MiCA CASP passport: A Crypto-Asset Service Provider authorized under MiCA in any EU Member State may provide services across all 27 EU Member States plus the EEA (Iceland, Liechtenstein, Norway) by notifying its home National Competent Authority (NCA) of the target states, service types, and start date. The host state NCA cannot impose additional authorization requirements.
Ireland's Central Bank (CBI),
France's AMF,
Germany's BaFin,
Luxembourg's CSSF, and
Liechtenstein's FMA all issue passportable MiCA CASP authorizations.
MiFID II investment services passport: Investment firms authorized under MiFID II may passport all Annex I investment services -- including those relating to tokenized securities classified as financial instruments -- across the EEA via freedom to provide services (notification-based, operational within one month) or right of establishment (branch notification, two-month host state response window).

Passporting is the strongest form of cross-border recognition because it eliminates the need for any host-state authorization. It applies only within integrated economic blocs with harmonized regulatory frameworks. Of the 21 jurisdictions surveyed, six benefit from EU/EEA passporting (

EU,

Source: AMLBot -- MiCA License Explained: CASP Requirements, Authorization & EU Passporting; Dechert -- Application of Second Part of MiCA

Liechtenstein,

Luxembourg); the

UAE operates a narrow intra-federation fund-passporting regime (ADGM/DIFC retail funds marketed onshore) but no securities-venue passport. The remaining 14 have no passport mechanism at all.

Model B: Equivalence and Recognition

Equivalence regimes permit firms from third countries to serve clients in the recognizing jurisdiction based on a determination that the third country's regulatory framework is "equivalent" in its outcomes. This model requires a formal assessment by the recognizing jurisdiction's authorities.

EU third-country equivalence under MiFID II: The European Commission may adopt equivalence decisions permitting third-country investment firms to provide services to eligible counterparties and professional clients. As of June 2026, no equivalence decisions have been adopted specifically addressing third-country frameworks for tokenized securities.
EU MiCA third-country access: MiCA does not provide an equivalence or recognition regime for third-country CASPs. Third-country firms must establish an EU legal entity and obtain MiCA authorization to serve EU clients.
UK equivalence determinations: Post-Brexit, the UK has the power to make equivalence determinations under its onshored MiFID framework. HM Treasury has engaged with IOSCO and the FSB on developing international standards that could support future deference or equivalence arrangements, but no equivalence determinations have been adopted for tokenized securities frameworks as of June 2026.
Switzerland equivalence: The EU granted MiFID II equivalence to Swiss trading venues in December 2017 but did not renew it from 1 July 2019. No EU mutual recognition of Swiss tokenized-securities venues currently applies.

No jurisdiction surveyed has an equivalence determination in force specifically for another's tokenized securities framework.

Source: Sidley Austin -- UK Cryptoasset Regulation Action Points for 2026-27

Model C: Bilateral Memoranda of Understanding (MoUs)

Bilateral MoUs between regulators establish information-sharing, cooperation, and in some cases mutual recognition of specific regulatory outcomes. These do not typically grant automatic market access but facilitate cross-border enforcement, supervisory cooperation, and coordinated oversight.

Key examples:

IOSCO Multilateral MoU (MMoU): Over 130 signatory jurisdictions commit to consultation, cooperation, and information exchange for securities markets enforcement. The Enhanced MMoU (EMMoU) provides additional tools including audit trail access and freezing of assets. Both instruments apply to tokenized securities activities by signatory regulators. Among the offshore and free-zone venues, Abu Dhabi's ADGM FSRA is an IOSCO MMoU signatory (cooperation with 100+ regulators), and the
Cayman Islands CIMA and BVI FSC participate in the international enforcement-cooperation architecture.
MAS-FCA joint report: In November 2025, the Monetary Authority of
Singapore and the UK Financial Conduct Authority published a joint report on "Aligning Digital Asset Offerings with Buy-Side Requirements," signaling bilateral regulatory cooperation on tokenized securities standards.
Singapore-China MoU: MAS entered an updated MoU on Financial Cooperation with the Chongqing Municipal Government, covering cross-border financing, fintech innovation, and green finance, with implications for tokenized asset flows between Singapore and China.

Source: IOSCO -- Multilateral Memorandum of Understanding; IOSCO -- Enhanced MMoU; MAS -- Singapore and China Deepen Financial Cooperation

Model D: Unilateral Recognition and Reverse Solicitation

Some jurisdictions permit foreign firms to serve domestic clients under limited conditions without formal authorization:

Reverse solicitation under MiCA: Article 61 of MiCA permits a third-country firm to provide crypto-asset services to an EU client where the client initiates contact at their own exclusive initiative. MiCA imposes strict conditions to prevent abuse: a CASP cannot solicit EU clients or promote services through marketing, and cannot subsequently expand services to that client beyond the specifically requested service. This is a narrow exception, not a viable market access strategy. It applies uniformly across all EU/EEA Member States, including
Ireland, whose third-country access otherwise runs through MiCAR reverse-solicitation carve-outs and AIFMD national private-placement regimes (NPPR).
UK Overseas Persons Exemption (OPE): The UK government has confirmed that the OPE will not be extended to regulated cryptoasset activities under the forthcoming regime (commencing 25 October 2027). Overseas firms providing cryptoasset services to UK retail consumers must obtain FCA authorization. Limited exceptions exist for B2B relationships where an overseas firm interacts solely with a UK-authorized broker-dealer meeting "directly related gateway" conditions.
US reverse solicitation: US securities law does not provide a formal reverse solicitation exemption. Foreign issuers accessing US investors must comply with SEC registration requirements or qualify for an exemption (Reg S, Rule 144A). Unsolicited transactions initiated by US investors in offshore markets may fall outside US jurisdictional reach in practice, but this is not a safe harbor and carries enforcement risk.
Offshore structuring venues (
Cayman, BVI): Neither the Cayman Islands nor the BVI grants any inbound recognition passport. Instead they function as outbound structuring domiciles: a Cayman or BVI issuer reaches EU professional investors only through host-state NPPR, and reaches US, UK, Singapore, or Hong Kong investors only through those jurisdictions' own exemptions. In the BVI, the sole issuance of a virtual asset is not in itself a VASP activity, so a non-SIBA token sale proceeds without a prospectus or FSC approval -- but that is a domestic carve-out, not cross-border recognition.

Source: Skadden -- A New UK Cryptoasset Framework; GOV.UK -- Regulatory Regime for Cryptoassets Policy Note

Model E: No Recognition -- Must Re-Register Locally

The default position in most jurisdictions is that foreign-issued tokenized securities receive no automatic recognition. A foreign issuer seeking to offer tokenized securities to local investors must comply with local prospectus, licensing, and conduct requirements in full. This is the prevailing position in the substantial majority of the 21 jurisdictions surveyed. It applies in, among others:

US: All securities offered or sold in the US must be registered with the SEC or qualify for an exemption, regardless of where they were issued or tokenized.
Japan: Tokenized securities classified as ERTRs must be distributed through JFSA-registered Type I Financial Instruments Business Operators.
Hong Kong: Tokenized securities offered to Hong Kong investors require SFC-licensed intermediaries (Type 1, 7, or 9 licenses).
Cayman Islands: Foreign tokenized securities are classified independently on substance under SIBA and the Mutual Funds / Private Funds Acts; no bespoke mutual-recognition regime exists.
Abu Dhabi (ADGM): A foreign-issued Digital Security is recognized only via the conventional Offer / Exempt-Offer / Approved-Prospectus routes (FSMR s. 58(2)(b) deeming); there is no broad mutual-recognition regime.

2. EU Passporting for Tokenized Securities

The EU provides the most comprehensive cross-border framework for tokenized assets, operating three parallel passport mechanisms. Six of the 21 jurisdictions in this domain rely on it directly: the

EU itself,

Source: Adam Smith -- MiCA Regulation 2026 Guide for Licensing; CAML -- Beyond the License: Choosing Your MiCA Home Base in 2026; Gofaizen & Sherle -- CASP License in Lithuania

Liechtenstein (EEA), and

Luxembourg.

2.1 MiCA CASP Passport

The MiCA passport applies to crypto-asset services for assets that do not qualify as financial instruments under MiFID II. It covers ten regulated activities including operation of trading platforms, custody and administration, exchange services, advisory services, portfolio management, and transfer services.

Passport mechanics:

Firm obtains CASP authorization from home NCA
Firm notifies home NCA of intended target Member States, services, and commencement date
Home NCA transmits notification to host NCAs
Firm may commence cross-border services upon notification (no host-state approval required)

Grandfathering limitation: Firms operating under national transitional provisions (grandfathered until 1 July 2026 at the latest) may continue operating only in their home Member State. The EU passport is available only upon receipt of full MiCA CASP authorization. Several jurisdictions shortened their transitional windows ahead of the EU default -- Germany and Lithuania to 31 December 2025, and

Ireland to 29 December 2025 (roughly six months early). As of mid-2025, more than 40 CASP licenses had been issued across EU Member States; among the early authorizations, Kraken (Payward) received a MiCAR CASP licence from the

Irish CBI in June 2025.

Source: Dechert -- Application of Second Part of MiCA; The Spotlite -- Cross-border Crypto Services in EU under MiCA

2.2 MiFID II Passport for Tokenized Securities

Where a tokenized asset qualifies as a financial instrument under MiFID II (tokenized bonds, equities, fund units, derivatives), the MiFID II passport -- not MiCA -- governs cross-border access. ESMA's nine classification guidelines published 19 March 2025 provide the authoritative framework for determining whether a tokenized asset is a financial instrument.

The MiFID II passport applies to all Annex I investment services:

Reception and transmission of orders
Execution of orders on behalf of clients
Dealing on own account
Portfolio management
Investment advice
Underwriting and placing
Operating an MTF or OTF

This means that a

Liechtenstein,
Luxembourg,
Ireland,
France, or
Germany-authorized investment firm dealing in tokenized bonds classified as MiFID II financial instruments can serve clients across all 30 EEA states under the MiFID II passport, not under MiCA. Funds add a third layer: a

Luxembourg UCITS or AIF, or an

Irish ICAV/QIAIF, with tokenized units passports across the EU under the UCITS / AIFMD marketing regimes.

2.3 DLT Pilot Regime Cross-Border Provisions

The DLT Pilot Regime (Regulation EU 2022/858) permits authorized DLT market infrastructures to operate across the EU. As of June 2026, six entities have been authorized per the ESMA register (January 2026):

CSD Prague (DLT SS, Czech Republic)
21X AG (DLT TSS,
Germany)
360X AG (DLT MTF,
Germany)
Axiology (Lithuania)
LISE SA (DLT TSS,
France)
Securitize (DLT TSS, Spain; venue on Avalanche, authorized by CNMV 26 Nov 2025)

The DLT Pilot Regime does not provide for third-country operators. All operators must hold EU authorization (as investment firms, market operators, or CSDs), and a Pilot permission is EU-wide.

Ireland's CBI is the Irish competent authority but, as of 4 June 2026, no Irish DLT-MTF/SS/TSS is confirmed live. The European Commission's Market Integration and Supervision Package (adopted 4 December 2025) would expand eligible operators to include MiCA-authorized CASPs and raise aggregate thresholds from EUR 6 billion to EUR 100 billion, making the regime permanent.

Source: ESMA -- DLT Pilot Regime; DLA Piper -- EU Capital Markets Overhaul

2.4 Cheapest MiCA Entry Point for Passporting

Because a single MiCA CASP authorization in any EU Member State provides EU-wide passporting rights, the choice of home Member State is a strategic cost-and-speed decision. Lithuania and

France represent the two most discussed entry points, with materially different profiles;

Ireland has emerged as a third credible option for fund- and institution-led models, given its dominant position as an EU MMF/ETF domicile.

Factor	Lithuania	France
NCA	Bank of Lithuania	AMF
Processing time	90-120 business days	150-180+ days
Application fee	EUR 2,500	Higher (varies by service)
Annual supervisory fee	0.6% of gross profits (min EUR 3,000)	AMF schedule
Capital requirements	EUR 50,000 / 125,000 / 150,000 (harmonized under MiCA)	Same (harmonized under MiCA)
Corporate tax rate	16%	25%
Compliance talent cost	30-40% lower than Amsterdam/Berlin	Higher
Transitional deadline	31 December 2025	1 July 2026
Regulatory ecosystem depth	Growing but limited	Deep (AMF, ACPR, Banque de France)

Lithuania has emerged as the most cost-effective EU entry point for MiCA passporting, combining faster processing, lower operating costs, and full EU-wide service coverage. France offers deeper regulatory infrastructure and proximity to EU institutional capital markets but at higher cost and longer timelines.

Ireland (CBI; MiCAR Art. 63 timetable of 25 + 40 working days plus a 5-day decision) is favored where the strategy is anchored to Irish-domiciled funds that underlie external tokenization platforms.

3. Post-Brexit UK-EU Divergence

3.1 Loss of Passporting

Following Brexit, UK-authorized firms lost the ability to passport financial services into the EU and EEA. Equally, EU-authorized firms lost the ability to passport into the UK. For tokenized securities, this means:

A UK FCA-authorized investment firm dealing in tokenized securities cannot serve EU retail or professional clients without establishing an EU-authorized entity.
An EU MiFID II-authorized firm cannot serve UK clients without FCA authorization or reliance on limited exemptions.
A UK firm authorized under the Digital Securities Sandbox (DSS) has no cross-border recognition in the EU.

3.2 UK Overseas Persons Exemption

The Overseas Persons Exemption under the UK's onshored MiFID framework permits third-country firms to provide certain regulated services to UK clients without FCA authorization under specific conditions. However, HM Treasury confirmed in December 2025 that the OPE will not be extended to the new regulated cryptoasset activities regime.

Overseas cryptoasset firms may still operate under limited conditions:

Interactions solely with a UK-authorized broker-dealer meeting "directly related gateway" conditions
Overseas custodians carrying out custody on instruction of a UK entity authorized for that activity
Serving only UK institutional clients (not acting as intermediary to UK consumers)

For all other activities involving UK retail consumers, full FCA authorization will be required from the regime's commencement date of 25 October 2027 (FSMA 2000 (Cryptoassets) Regulations 2026, SI 2026/102, made 4 February 2026).

Source: Latham & Watkins -- UK Cryptoasset Regime Key Takeaways; Sidley Austin -- UK Cryptoasset Regulation Action Points 2026-27

3.3 UK Equivalence Determinations

As of June 2026, the UK has not adopted equivalence determinations for any jurisdiction's tokenized securities or cryptoasset framework. HM Treasury retains the statutory power to make such determinations under the onshored EU legislation but has indicated that progress depends on the development of international standards through IOSCO and the FSB.

3.4 Impact on Tokenized Securities Market

The loss of passporting has created a bifurcated market:

EU-facing issuers use
Liechtenstein (EEA member with TVTG Token Container Model),
Luxembourg (Blockchain Laws I-IV),
Ireland (fund-domicile MMF/ETF base with MiCAR CASP and DLT Pilot access), or Lithuania (cost-effective MiCA entry) as EU market access points.
UK-facing issuers must engage FCA-authorized intermediaries or enter the Digital Securities Sandbox (16 Gate 1 entrants including HSBC, J.P. Morgan, Euroclear, and Tradeweb as of December 2025).
Dual-jurisdiction issuers maintain separate EU and UK entities, increasing cost and complexity.

The divergence is particularly significant for tokenized fund products: a

Luxembourg- or

Ireland-domiciled UCITS with tokenized units can be marketed across the EU under the UCITS passport but has no automatic access to UK investors. Conversely, a UK fund with tokenized units cannot be distributed in the EU without compliance with AIFMD marketing requirements in each target state.

4. Asia-Pacific Cross-Border

4.1 Singapore: Project Guardian and GL1

Singapore has pursued a multilateral, infrastructure-led approach to cross-border tokenization through two flagship initiatives.

Project Guardian is a collaborative initiative launched by MAS in 2022 with over 40 industry participants including DBS, JPMorgan (Kinexys), Standard Chartered, HSBC, OCBC, UBS, Citi, MUFG, Franklin Templeton, and Societe Generale-FORGE. The project has conducted over 15 trials of tokenization across fixed income, funds, FX, and structured products in six currencies. Key international outputs include:

The Guardian Fixed Income Framework (November 2024), developed with ICMA, CMTA, and GFMA
An Operational Guide for Tokenized Funds (November 2025)
A joint FCA-MAS report on "Aligning Digital Asset Offerings with Buy-Side Requirements" (November 2025)

Global Layer One (GL1) was launched by MAS in June 2024 to develop shared ledger infrastructure for regulated financial institutions across jurisdictions. GL1 establishes common settlement rules, data formats, and cross-network connectivity for tokenized asset interoperability.

GL1 participants include:

Core members (June 2024): BNY, Citi, JPMorgan, MUFG Bank, Societe Generale-FORGE
Expanded members (November 2024): Euroclear, HSBC
Central bank observers: European Central Bank, Banque de France, Bank of England, MAS, International Monetary Fund

GL1 published two toolkits in 2025 for the development and adoption of regulated tokenized asset networks, with plans to establish a non-profit organization (GL1 Org) to develop common principles, policies, and standards.

BLOOM, launched in October 2025, extends Singapore's settlement capabilities by enabling real-time cross-border settlement for tokenized assets using tokenized MAS bills settled via CBDC for overnight interbank lending.

Singapore's own cross-border posture remains conservative. There is no broad mutual-recognition framework for foreign-issued tokenized securities; the recognised-offers pathway (s276 SFA) handles secondary sales of exemption-acquired securities, and the FSMA DTSP regime is extraterritorial -- Singapore corporations/individuals operating from Singapore are in scope even when serving only overseas clients (MAS grants DTSP licences only in "extremely limited circumstances").

Source: MAS -- Project Guardian; MAS -- GL1 Whitepaper (May 2024); Ledger Insights -- Global Layer One launches tokenized asset toolkits; BIS -- Leong Sing Chiong speech (November 2024)

4.2 Hong Kong-Singapore Cooperation

Hong Kong and Singapore represent the two leading Asian financial centres for tokenized securities regulation, each with mature frameworks:

Singapore: SFA-based regulation with CMS licensing, RMO framework (ADDX, InvestaX), and DBS Digital Exchange
Hong Kong: SFO-based regulation with SFC Type 1/7/9 licensing, VATP licensing under AMLO, and the HKSAR Government tokenized green bond program (three issuances; the third was a HKD 10 billion multi-currency digital green bond in November 2025)

Cross-border cooperation operates primarily through:

HKMA's Project Ensemble exploring wholesale CBDC-based settlement of tokenized assets (the EnsembleTX real-value pilot launched 13 November 2025, operating through 2026)
SFC's ASPIRe roadmap (February 2025) emphasizing international cooperation as one of five pillars
SFC permission for VATPs to share global order books with overseas affiliates, connecting Hong Kong markets with global liquidity
BIS Project mBridge connecting Hong Kong, Thailand, China, Saudi Arabia, and the UAE for cross-border CBDC settlement

No formal bilateral mutual recognition agreement for tokenized securities exists between Hong Kong and Singapore as of June 2026. Cross-border activity relies on parallel compliance with both jurisdictions' frameworks.

Source: SFC -- ASPIRe Roadmap; InvestHK -- Hong Kong Fintech Ecosystem Report 2025

4.3 Japan and South Korea: Domestically Oriented Frameworks

Japan's ERTR (Electronically Recorded Transferable Rights) framework under the FIEA is largely domestic in orientation. The JFSA has pursued international engagement through:

Participation in IOSCO's Fintech Task Force, which produced the 18 CDA Recommendations (November 2023) and the Tokenization of Financial Assets Final Report (November 2025)
The FSA's April 2025 discussion paper on crypto-asset classification reform, and a subsequent FIEA crypto-asset reclassification bill cabinet-approved 10 April 2026 (pending Diet, expected effective ~FY2027), which references international regulatory convergence
JFSA participation in IOSCO MMoU/EMMoU enforcement cooperation
Japan's participation in BIS Project Agora as one of seven central banks exploring cross-border tokenized payment settlement

Japan does not maintain a formal mutual recognition or equivalence framework for foreign-issued tokenized securities. Foreign issuers seeking access to Japanese investors must distribute through JFSA-registered Type I Financial Instruments Business Operators. The Japanese public ST market reached cumulative JPY 333.3 billion by FY2025 (BOOSTRY ST Market Report, April 2026).

South Korea is similarly inward-facing. Its STO framework (FSCMA/AERSB amendments passed 15 January 2026, effective January 2027) mandates centralized KSD registration -- more centralized than Singapore or the UAE -- and the file records no passporting, mutual-recognition, or third-country tokenized-securities regime; cross-border access defaults to local re-registration.

Source: GLI -- Blockchain & Cryptocurrency Laws 2026: Japan; Nomura/BOOSTRY -- Japan ST Market Report FY2025

4.4 ASEAN Cross-Border Initiatives

ASEAN-level coordination on tokenized assets remains at an early stage but is accelerating:

ASEAN Digital Economy Framework Agreement (DEFA): Set to become the world's first region-wide agreement focused on digital economy governance, DEFA is designed to harmonize digital trade rules and enable cross-border data flows across ASEAN. Negotiations are due to conclude in 2026.
Project Nexus: Connects Singapore's payment infrastructure with Thailand, Indonesia, and Malaysia for cross-border transactions. While not specific to tokenized securities, this infrastructure is expected to support settlement for tokenized assets as the market matures.
Malaysia's 2025 ASEAN Chairmanship: Positioned Malaysia to lead regional discussions on digital asset policy harmonization and cross-border regulatory cooperation.

No ASEAN-wide mutual recognition framework for tokenized securities exists. Each ASEAN member state maintains independent securities regulation.

Source: WEF -- ASEAN Takes Major Step Toward Digital Economy Pact; ADB -- Technological Advances in Financial Market Infrastructure in ASEAN+3

5. US Market Access for Foreign RWA Tokens

The United States presents the most restrictive market access environment for foreign-issued tokenized securities. No equivalence, recognition, or passporting framework exists, and cross-border coordination remains a Crypto Task Force priority area rather than an operational regime. Foreign issuers must navigate specific exemptions under federal securities law.

5.1 Regulation S Safe Harbor

Regulation S exempts offshore offerings from SEC Section 5 registration, provided two conditions are met: (1) each offer and sale occurs in an offshore transaction, and (2) no directed selling efforts are made in the United States. This is the primary exemption used by non-US tokenized securities issuers -- including those structured through

Cayman, BVI, or other offshore domiciles -- to avoid US registration.

Reg S includes three issuer categories with increasing restrictions:

Category	Typical Issuer	Distribution Compliance Period	Key Restrictions
Category 1	Foreign issuer, no US market interest	None	Minimal
Category 2	SEC-reporting foreign private issuer	40 days	Offering and transactional restrictions
Category 3	Domestic issuer or non-Cat 1/2 debt	6 months (equity) / 40 days (debt)	Certification, legending, purchaser agreements

Smart contract-enforced transfer restrictions are particularly effective for Reg S compliance, programmatically preventing transfers to US-based wallets during the distribution compliance period (Rules 903/904 offshore safe harbors).

Source: SEC -- Regulation S; RWA.io -- RWA Tokenization USA: Reg D and Reg S

5.2 Rule 144A for Qualified Institutional Buyers

Rule 144A permits resales of restricted securities to Qualified Institutional Buyers (QIBs) -- institutions owning and investing at least $100 million in securities -- without SEC registration. This is the primary mechanism for institutional cross-border secondary trading of tokenized securities in the US.

Rule 144A benefits:

No holding period requirement (unlike Rule 144's 6-12 months)
No public information requirement
Immediate resale eligibility among QIBs
Most institutional tokenized securities platforms (Securitize, tZERO) facilitate Rule 144A trading

The combination of Reg S (offshore primary) and Rule 144A (US institutional secondary) is the standard architecture for global tokenized securities offerings that include US institutional distribution.

5.3 No-Action Letter Approaches and the Nasdaq Approval

The SEC's Crypto Task Force (established under Chairman Atkins' "Project Crypto" initiative) has pursued a no-action letter strategy alongside targeted formal approvals for tokenized securities:

Nasdaq tokenized-securities approval (18 March 2026): The SEC approved Nasdaq trading of tokenized securities (Release 34-105047), with go-live targeted for Q3 2026. Notably, these tokenized trades settle T+1 conventionally through NSCC/DTC rails -- not on an atomic/T+0 on-chain basis.
DTC Tokenization Pilot (no-action 11 December 2025): SEC Division of Trading and Markets permitted a three-year pilot to tokenize DTC-custodied assets (Russell 1000 constituents, US Treasuries, S&P 500/Nasdaq-100 ETFs) on supported blockchains.
Rule 506(c) verification (12 March 2025): No-action letter providing that self-certification combined with minimum investment amounts satisfies accredited investor verification for tokenized offerings.

The 28 January 2026 SEC three-division joint statement set out the two-category framework (issuer-sponsored vs. third-party tokenized securities). These approvals and no-action letters provide regulatory comfort for specific use cases but do not create formal cross-border recognition frameworks.

Source: SEC -- Statement on Tokenized Securities (January 28, 2026); SEC Commissioner Peirce -- Tokenization Trending (December 11, 2025)

5.4 Reverse Solicitation Limitations

The US does not have a statutory reverse solicitation exemption analogous to MiCA Article 61. In practice, foreign issuers may rely on the general principle that US jurisdiction attaches only to offers and sales that occur "in" the United States or are "directed at" US persons. However:

The SEC has consistently taken a broad view of US jurisdictional reach
Digital distribution channels (websites, social media, DeFi protocols) create presumptive US-directed activity unless affirmative geofencing measures are implemented
No safe harbor exists for purely passive online availability of tokenized securities to US persons

Reliance on reverse solicitation is high-risk and not advisable as a primary US market access strategy.

6. Offshore and Fund-Domicile Venues: Cayman, BVI, Ireland, and ADGM

The four jurisdictions added in this refresh share a common structural role -- they are issuer, fund, and SPV domiciles rather than retail-distribution markets -- but they split sharply on cross-border recognition.

6.1 Cayman Islands and BVI: Third-Country Structuring Domiciles

Neither the

Cayman Islands nor the British Virgin Islands is part of any passporting bloc, and neither operates a mutual-recognition regime for foreign-issued tokenized securities.

Cayman Islands: No passporting (non-EU/non-US third country); EU investors are reached only via national private-placement regimes (NPPR). The 2026 tokenised-funds framework (in force 24 March 2026) channels "digital equity tokens" / "digital investment tokens" into the existing SIBA and Mutual Funds / Private Funds regimes, classifying foreign tokenized instruments independently on substance -- it does not import any foreign authorization. Cross-border legitimacy rests on FATF alignment (Recommendations 15/16, Travel Rule; removed from the FATF grey list October 2023) and CRS/FATCA/CARF information exchange.
BVI: No passporting and no mutual-recognition passport for VASPs. The VASP Act 2022 is built to FATF standards (Travel Rule), and the BVI participates in OECD automatic exchange of information (CRS, CRS 2.0 effective 1 January 2026, and CARF effective for the 2027 calendar year with first reports due to the ITA in 2028). English common law with final appeal to the UK Privy Council underpins cross-border enforceability. As in Cayman, a Cayman/BVI issuer reaches EU professional investors only through host-state NPPR and reaches US/UK/Asia investors only via those markets' own exemptions.

6.2 Ireland: Full EU Passporting Member

Ireland is the cross-border outlier among the four -- a full EU passporting member rather than a third country. EU passporting is its core mechanism: MiFID, MiCAR CASP (across 30 EEA states), AIFMD/UCITS, and DLT Pilot permissions all carry EU-wide effect. There is no separate Irish mutual-recognition regime for third-country tokenized securities beyond the EU framework; Ireland aligns with ESMA convergence and EU-level policy. Third-country access into Ireland runs through MiCAR reverse-solicitation and limited carve-outs plus AIFMD national private-placement regimes. Ireland's distinctive contribution is as the underlying EU MMF/ETF fund-domicile that other jurisdictions' tokenization platforms (e.g. JP Morgan Kinexys, Archax) plug into.

6.3 Abu Dhabi (ADGM): Common-Law Single-Regulator Free Zone

Abu Dhabi's ADGM (regulated by the FSRA under the FSMR) grants no automatic passporting of its Digital Securities authorizations into other jurisdictions. The only passport-like mechanism is the intra-UAE fund-passporting regime, which permits ADGM/DIFC retail funds to be marketed onshore. There is no broad mutual-recognition regime for foreign-issued Digital Securities; recognition of a foreign offer proceeds only through the conventional Offer / Exempt-Offer / Approved-Prospectus routes, all of which still depend on FSMR s. 58(2)(b) deeming. For cross-border cooperation, ADGM relies on its IOSCO MMoU signatory status (cooperation with 100+ regulators), bilateral arrangements, UAE fund-passporting, and case-by-case FSRA engagement, layered on UAE federal AML/CFT law, FATF Recommendations, and FATCA / ADGM CRS Regulations 2017.

Source: matrix-derived from

Cayman Islands, British Virgin Islands,

Ireland, and Abu Dhabi (ADGM) regulation files; IOSCO -- MMoU

7. Will a Token Issued in
Switzerland Be Recognized in
Singapore?

This section provides concrete regulatory paths for specific cross-border scenarios involving tokenized securities.

Scenario 1: Swiss-Issued Tokenized Bond -- Singapore Distribution

Issuance: A Swiss company issues a tokenized corporate bond as a ledger-based security (Registerwertrecht) under Art. 973d of the Swiss Code of Obligations, registered on a DLT platform such as SDX or BX Digital. The bond qualifies as an "asset token" under FINMA's classification and complies with FinSA prospectus requirements.

Singapore recognition path:

The tokenized bond constitutes a "debenture" under Singapore's SFA (s. 2), triggering full capital markets regulation.
A prospectus is required unless an exemption applies. The most likely exemptions are: institutional investors only (s. 274 SFA), accredited investors (s. 275 SFA, minimum S$200,000 investment per transaction), or small offers (s. 272A SFA, capped at S$5 million in 12 months).
Distribution requires engagement of a CMS-licensed intermediary (dealing in securities) in Singapore.
Custody must comply with SFA custody requirements, including segregation and risk disclosure obligations.
No automatic recognition of the Swiss prospectus, FINMA authorization, or Swiss legal classification applies. The substance of the token's rights determines Singapore regulatory treatment.

Practical architecture: The Swiss issuer engages a Singapore CMS-licensed platform (e.g., ADDX, InvestaX, or a CMS-licensed bank such as DBS) to distribute the tokenized bond to Singapore accredited and institutional investors under SFA prospectus exemptions. Separate compliance with Swiss FinSA/AMLA and Singapore SFA/MAS requirements is required.

Scenario 2: EU-Issued Tokenized Fund Unit -- US Distribution

Issuance: A

Luxembourg-domiciled RAIF (or an

Ireland-domiciled QIAIF) issues tokenized fund units on DLT under Blockchain Law IV (Luxembourg) or the EU/CBI framework (Ireland). The AIFM holds a CSSF (Luxembourg) or CBI (Ireland) authorization.

US recognition path:

The tokenized fund units constitute securities under the Howey test (investment of money, common enterprise, expectation of profits from others' efforts).
The fund is an "investment company" under the Investment Company Act of 1940 unless it qualifies for an exemption (Section 3(c)(1) -- max 100 US investors; Section 3(c)(7) -- qualified purchasers only).
Offering must comply with Reg D Rule 506(c) (accredited US investors) and/or Rule 144A (QIBs for secondary).
The fund must engage a SEC-registered broker-dealer (e.g., Securitize Markets) and transfer agent.
No recognition of the Luxembourg CSSF / Irish CBI authorization, EU AIFMD passport, or MiCA-related approvals applies in the US.

Scenario 3: Hong Kong-Issued Tokenized Green Bond -- EU Distribution

Issuance: The HKSAR Government issues a tokenized green bond (as in its multi-issuance program, including the HKD 10 billion multi-currency third digital green bond of November 2025).

EU recognition path:

The tokenized bond constitutes a "transferable security" under MiFID II.
A prospectus approved by an EU NCA is required under the Prospectus Regulation (EU) 2017/1129 unless exemptions apply (qualified investors only, minimum EUR 100,000 denomination, or fewer than 150 non-qualified investors per Member State).
Distribution requires a MiFID II-authorized investment firm in the EU (which, once authorized in any one Member State -- e.g.
Ireland,
France, or
Germany -- can passport across the EEA).
No recognition of Hong Kong SFC authorization or HKMA regulatory approvals applies in the EU.
Hong Kong is not subject to an EU equivalence determination for securities regulation.

Scenario 4: Cayman-Domiciled Tokenized Fund -- EU and US Distribution

Issuance: A

Cayman Islands registered mutual fund issues tokenised fund interests as a "digital investment token" under the 2026 tokenised-funds framework, structured through an exempted company or SPC.

Cross-border recognition path:

No passport, no equivalence. Cayman is a third country for both the EU and US; the Cayman registration confers no recognition abroad.
EU access: professional investors are reached only through host-state national private-placement regimes (NPPR) under AIFMD; there is no MiCA or MiFID passport.
US access: the offering must rely on Reg S (offshore primary) and Reg D 506(c) / Rule 144A (US accredited / QIB), with smart-contract transfer restrictions preventing US flowback.
Cooperation backbone: FATF alignment and CRS/FATCA/CARF exchange support the structure's international acceptability, but they are information-sharing instruments, not market-access grants.

8. Comparative Table

The following table summarizes the cross-border recognition mechanisms available when moving tokenized securities between major jurisdictions. The origin column now includes the four jurisdictions added in this refresh (

Cayman Islands, BVI,

Ireland, and Abu Dhabi / ADGM).

Origin	Target: EU	Target: US	Target: UK	Target: Singapore	Target: HK	Primary Mechanism
EU Member State	MiCA passport (crypto-assets) / MiFID II passport (securities)	Reg S / Rule 144A / Reg D	No passport; FCA auth required	CMS-licensed intermediary; SFA exemptions	SFC-licensed intermediary; SFO applies	EU: passport; others: local compliance
Ireland	EU passport (MiFID / MiCAR CASP / UCITS-AIFMD / DLT Pilot)	Reg S / Rule 144A / Reg D	No passport; FCA auth required	CMS-licensed intermediary	SFC-licensed intermediary	EU: passport; others: local compliance
UK	No passport; EU entity required	Reg S / Rule 144A / Reg D	Domestic (FCA auth / DSS)	CMS-licensed intermediary	SFC-licensed intermediary	Local compliance in each target
Switzerland	No passport (non-EEA); EU entity required	Reg S / Rule 144A	FCA auth required	CMS-licensed intermediary	SFC-licensed intermediary	Local compliance; no recognition
Singapore	EU entity required; no equivalence	Reg S / Rule 144A	FCA auth required	Domestic (SFA / CMS)	SFC-licensed intermediary	Local compliance in each target
Hong Kong	EU entity required; no equivalence	Reg S / Rule 144A	FCA auth required	CMS-licensed intermediary	Domestic (SFO / SFC)	Local compliance in each target
Japan	EU entity required; no equivalence	Reg S / Rule 144A	FCA auth required	CMS-licensed intermediary	SFC-licensed intermediary	Local compliance in each target
Liechtenstein	MiFID II passport (EEA); MiCA passport (EEA)	Reg S / Rule 144A	No passport; FCA auth required	CMS-licensed intermediary	SFC-licensed intermediary	EEA: passport; others: local compliance
Cayman Islands	No passport; AIFMD NPPR (professional)	Reg S / Rule 144A / Reg D	FCA auth required	CMS-licensed intermediary	SFC-licensed intermediary	Third-country structuring; local compliance
BVI	No passport; AIFMD NPPR (professional)	Reg S / Rule 144A / Reg D	FCA auth required	CMS-licensed intermediary	SFC-licensed intermediary	Third-country structuring; local compliance
Abu Dhabi (ADGM)	No passport (third country); AIFMD NPPR	Reg S / Rule 144A / Reg D	FCA auth required	CMS-licensed intermediary	SFC-licensed intermediary	IOSCO MMoU cooperation; local compliance

Key observation: Outside the EU/EEA passporting bloc, there is no jurisdiction pair that offers automatic mutual recognition for tokenized securities. Of the 21 jurisdictions surveyed, only the six EU/EEA members (

EU,

Source: UNIDROIT -- Digital Assets and Private Law Project; HCCH -- HCCH-UNIDROIT Digital Assets and Tokens Joint Project; UNIDROIT -- Implementation Strategy C.D. (105) 21

Liechtenstein,

Luxembourg) enjoy a genuine cross-border passport; the

UAE has only an intra-federation fund passport. Every cross-border transaction outside the EU/EEA requires parallel compliance with both origin and target jurisdiction regulatory frameworks.

9. Regulatory Cooperation Mechanisms

9.1 IOSCO MMoU and EMMoU

The IOSCO Multilateral Memorandum of Understanding Concerning Consultation and Cooperation and the Exchange of Information (MMoU), signed by over 130 securities regulators globally, is the foundational instrument for cross-border securities enforcement cooperation. The Enhanced MMoU (EMMoU) provides additional powers including compulsion of audit trail information, compulsion of testimony, and freezing of assets. Among the 21 jurisdictions surveyed, the MMoU is the single most widely shared cooperation backbone -- explicitly relied on by, among others, Abu Dhabi's ADGM FSRA (100+ regulators),

Brazil,

Canada,

Japan, and the offshore venues (

Cayman, BVI).

For tokenized securities, the MMoU and EMMoU are relevant because:

They enable cross-border enforcement investigations involving tokenized securities fraud, market manipulation, and unauthorized offerings
They support supervisory cooperation for firms operating across multiple jurisdictions
IOSCO's October 2025 thematic review on implementation of the 18 CDA Recommendations assessed cross-border cooperation as a key area requiring improvement

IOSCO's 2026 work program includes a formal methodology for crypto and digital asset assessments and continued monitoring of tokenization developments.

Source: IOSCO -- MMoU; Tokenizer Estate -- IOSCO 2026 Plan

9.2 BIS Cross-Border DLT Projects

The BIS Innovation Hub operates several projects directly addressing cross-border tokenized asset settlement:

Project Agora is the flagship cross-border tokenized payments initiative, bringing together seven central banks -- Bank of France (Eurosystem), Bank of Japan, Bank of Korea, Bank of Mexico, Swiss National Bank, Bank of England, and the Federal Reserve Bank of New York -- with 43 regulated financial institutions. The project explores a unified programmable ledger combining tokenized central bank and commercial bank money for wholesale cross-border settlement. As of September 2025, the project had moved from design to prototype building, with a report expected in H1 2026.

Project Promissa (final report April 2025, BIS/SNB/World Bank) demonstrated tokenization of government promissory notes across seven countries, compressing encashment timescales from weeks to seconds and eliminating record reconciliation requirements.

Project Guardian (BIS Innovation Hub/MAS) conducted over 15 trials of tokenization in six currencies, with the November 2024 Guardian Fixed Income Framework providing practical guidance on settlement assets including wholesale CBDC, tokenized bank liabilities, and regulated stablecoins.

Project Mandala explores pre-screening capabilities and jurisdiction-specific policy encoding for cross-border compliance, aiming to automate regulatory compliance checks across borders using encoded rules on DLT platforms.

Source: BIS -- Project Agora; BIS -- Project Promissa Final Report (April 2025); MAS -- Project Guardian

9.3 UNIDROIT Principles and Conflict of Laws

The UNIDROIT Principles on Digital Assets and Private Law (adopted May 2023, published October 2023) address the foundational private law questions underlying cross-border tokenized asset transactions.

Conflict of laws waterfall (Principle 5): UNIDROIT establishes a hierarchy for determining applicable law:

Law specified in the digital asset itself
Law specified in the system or platform
Law of the issuer's jurisdiction
Forum state's discretion

HCCH-UNIDROIT Joint Project on Applicable Law: Launched in 2023, this project examines the desirability and feasibility of a normative framework on the law applicable to cross-border holdings and transfers of digital assets and tokens. In March 2025, the HCCH Council on General Affairs and Policy mandated establishment of an Experts' Group to study private international law issues raised by digital tokens. The project addresses whether the PRIMA (Place of the Relevant Intermediary Approach) rule from the HCCH Securities Convention works for DLT-based custody.

This work is directly relevant because cross-border tokenized securities transactions raise unresolved questions about which jurisdiction's law governs ownership, transfer, custody, and insolvency -- questions that existing securities conflict-of-laws rules were not designed to answer for borderless digital assets. The offshore structuring domiciles add a further wrinkle: a

Cayman or BVI SPV issuing under English-derived common law, holding assets governed by another jurisdiction's law and serving investors in a third, is precisely the multi-jurisdiction fact pattern UNIDROIT's waterfall is designed to resolve.

10. What Works and What Doesn't

What Works

EU passporting is the only operational cross-border recognition framework for tokenized assets. The combination of MiCA (for crypto-assets not qualifying as financial instruments) and MiFID II (for tokenized securities qualifying as financial instruments) provides genuine single-market access across 30 EEA states, benefiting six of the 21 jurisdictions surveyed (

EU,