Regulation & jurisdiction intelligence

Tokenized fund interests are securities. Distribution runs through registered offerings or private placement exemptions; the token is a representation of the security, not a separate instrument.

Registered money market funds may maintain an on-chain share register through an SEC-registered transfer agent. Non-registered funds rely on Reg D / 3(c)(7) with qualified purchaser gating.

Fund assets sit with a bank or trust-company custodian. On-chain positions require a qualified custodian or a registered transfer agent of record.

Tokenized fund units are transferable securities under MiFID II. The DLT Pilot Regime provides a sandbox for DLT market infrastructures with volume caps.

Short-term VNAV and LVNAV money market funds may issue tokenized share classes. The fund remains subject to full MMFR portfolio and liquidity constraints regardless of the register technology.

A licensed depositary must safekeep fund assets. MiCA custody rules apply to crypto-asset service providers but not to tokenized securities, which remain under MiFID II.

Tokenized collective investment scheme units are capital markets products. Offers rely on restricted-scheme or accredited-investor exemptions unless the scheme is authorised for retail.

The VCC gives tokenized funds a purpose-built corporate wrapper with segregated sub-funds. Project Guardian provides the supervised environment in which institutions pilot tokenized asset distribution.

Custody of tokenized securities sits with a licensed capital markets services provider; digital token custody is separately licensed under the FSM Act.

Tokenisation changes the register, not the instrument: a tokenised security remains a security under FSMA and is distributed under the existing perimeter. Wholesale settlement experiments run inside the Digital Securities Sandbox rather than outside the rules.

Authorised funds may maintain a tokenised register within the existing authorised-fund regime. The policy statement finalised rules and guidance rather than creating a separate tokenised-fund category, so an authorised fund keeps its permissions when it tokenises.

Fund assets sit with an FCA-authorised custodian under CASS. Prudential and safeguarding rules for qualifying cryptoassets were finalised through 2026 and are being brought into force in stages.

Swiss law recognises the ledger-based security as a class of its own: rights are constituted on the ledger rather than represented by a certificate, so transfer on-chain is transfer at law. Bonds, notes, structured products and certain fund interests are all issued this way.

Collective investment schemes remain under CISA; the DLT Act supplies the register. A FINMA-licensed fund management company and custodian bank are still required, which is why Swiss tokenised funds look conventional in structure and unconventional only in settlement.

Crypto-based assets held for clients are segregated from the custodian's balance sheet and excluded from its bankruptcy estate. FINMA Guidance 01/2026 sets the supervisory floor for compliant custody.

A tokenised security is a security: the SFC treats tokenisation as a change of form and requires the same licensing for dealing and distribution. Its framework has been extended to cover tokenised gold and other real-world assets on licensed platforms.

Authorised funds may tokenise their register. The 2026 Policy Address commits to letting regulated stablecoins settle tokenised money market funds, putting tokenised deposits, wholesale central bank money and licensed stablecoins on one settlement rail under EnsembleTX.

Client assets sit with a licensed custodian under SFC expectations. A digital-asset custody monitoring system is due in the second half of 2026, with market and anti-money-laundering surveillance following in 2027.

There is no single national regime. An issuer inside ADGM or the DIFC follows that free zone's rulebook; Dubai outside the DIFC falls to VARA, and onshore activity to the federal authorities. Which regulator applies is a function of where the issuer is established, not of the instrument.

Tokenised fund units are offered under the free-zone fund rules with the usual manager and custodian requirements. Tokenisation of real-world assets is explicitly contemplated rather than tolerated.

Custody is a licensed activity in each free zone. ADGM's FSRA finalised an expanded fiat-referenced token regime covering custody, intermediation and acceptance, effective 1 January 2026.