Tokenization Compliance
Intelligence

What Is Tokenization Compliance?

Tokenization compliance encompasses the regulatory requirements, licensing obligations, and operational standards governing the issuance, distribution, trading, and custody of tokenized assets. As traditional financial instruments—from real estate and bonds to equities and money market funds—are increasingly represented as digital tokens on distributed ledger technology, every major jurisdiction is developing its own framework to regulate this activity.

The challenge for market participants is that tokenization sits at the intersection of securities law, payment regulation, data protection, anti-money laundering (AML) requirements, and emerging digital asset legislation. A single tokenized real estate offering may simultaneously trigger obligations under securities regulation, property law, consumer protection rules, AML/KYC requirements, and cross-border transfer restrictions.

Compliance is not optional. The EU's Markets in Crypto-Assets Regulation (MiCA) is fully enforced. Dubai's Virtual Assets Regulatory Authority (VARA) is actively licensing and sanctioning. The U.S. Securities and Exchange Commission issued a landmark joint staff statement on tokenized securities in January 2026, clarifying that tokenization changes the plumbing but not the regulatory perimeter. For in-depth SEC tracking, see SECTokenization.com.

The 2026 Regulatory Landscape

The tokenized asset market has entered a period of institutional acceleration. According to industry data, the real-world asset tokenization market reached $24 billion in 2025—a 308% increase in three years. Tokenized Treasury and money market fund products surged to $7.4 billion, and the World Economic Forum identified 2026 as a defining year for scaling digital asset solutions.

Several converging forces are reshaping the compliance landscape. The GENIUS Act, signed into law in 2025, established the first U.S. federal regulatory framework for stablecoins, requiring 100% reserve backing and monthly disclosures. The CLARITY Act, currently moving through Congress, would standardise how digital commodities are defined and create registration requirements for brokers and dealers. Meanwhile, GCC states—particularly Dubai, Saudi Arabia, and Bahrain—are building competing frameworks to attract tokenization platforms. For analysis of emerging tokenization policy globally, see our sister publication.

The CFTC launched its year-long "Crypto Sprint" in August 2025, focusing on listing spot digital assets on registered exchanges and enabling derivatives market participants to use tokenized collateral, including stablecoins. In December 2025, CFTC staff issued guidance allowing futures commission merchants and clearing organisations to accept tokenized collateral for the first time. For corporate governance frameworks around these developments, see our dedicated coverage.

Global Regulatory Frameworks Compared

Tokenization regulation now falls into five categories: comprehensive dedicated legislation (the EU's MiCA), evolving federal legislation (the U.S. GENIUS Act plus anticipated CLARITY Act), dedicated licensing regimes (the GCC model), principles-based frameworks (Switzerland's DLT Act), and frameworks still in consultation (the UK's approach).

Cross-border interoperability remains the most critical unresolved challenge. For detailed UAE regulatory analysis, Saudi tokenisation tracking, and Dubai VARA licensing intelligence, see our dedicated jurisdictional publications.

Jurisdiction-by-Jurisdiction Analysis

Each jurisdiction's approach reflects its broader regulatory philosophy and positioning in the race to attract digital asset capital. Select a jurisdiction below for comprehensive compliance intelligence.

The U.S. Regulatory Shift

The U.S. regulatory landscape for tokenized assets changed dramatically in 2025. As documented by Cleary Gottlieb, regulators shifted from enforcement-heavy skepticism to a determined focus on enabling market participation. The SEC dropped nearly all enforcement actions against fintechs that lacked accompanying fraud allegations, and began issuing no-action relief to digital asset issuers.

The most significant development was the DTC no-action letter issued December 11, 2025, allowing the Depository Trust Company—which handles custody for the majority of U.S. securities—to begin piloting tokenization services in 2026. DTC can now represent certain custodied securities as tokens on approved blockchains, with participant wallets screened for OFAC compliance. The pilot launches in the first half of 2026, with public rollout planned for the second half. This effectively creates a pathway to tokenize nearly all U.S. equities. For ongoing SEC enforcement and no-action tracking, see SECTokenization.com.

On January 28, 2026, SEC staff from the Divisions of Corporation Finance, Trading and Markets, and Investment Management jointly issued guidance clarifying how existing securities laws apply to tokenization structures. The guidance confirmed that tokenization changes the recording technology but not the regulatory classification—a tokenized stock remains an equity security under the Securities Act and Exchange Act.

Looking ahead, Congress appears poised to adopt a comprehensive market infrastructure bill that would establish regulatory regimes for digital asset brokers, dealers, and exchanges. As K&L Gates notes, the key theme for 2026 is the democratisation of digital assets—making them accessible without fear of enforcement action.