‍1. Executive Summary

The global financial system stands at a precipice of transformation comparable to the dematerialization of paper securities in the 1970s. We are witnessing the migration of financial assets from isolated, legacy electronic ledgers to interoperable, programmable distributed ledger technology (DLT). With that in mind, this report will provide an exhaustive, institutional-grade analysis of the market for security tokens, tokenized Real-World Assets (RWAs), and digital participative financial instruments, covering developments from late 2024 through 2025.

Current market data indicates a sector in the midst of a sharp acceleration. While the broader cryptocurrency market remains subject to volatility and speculative cycles, the regulated digital securities market appears to be decoupling from the broader crypto market, driven by fundamental utility: yield, collateral mobility, and operational efficiency. By mid-2025, the on-chain RWA market, strictly excluding non-yielding stablecoins, had surpassed a valuation of $30 billion, with some metrics suggesting a trajectory toward $50 billion by year-end. It is important to note that figures vary by dataset and scope; unless noted, RWA market size here excludes stablecoins and includes tokenized Treasuries, private credit, and other yield-bearing RWAs.

Nevertheless, this growth is not evenly distributed; it is heavily concentrated in High-Quality Liquid Assets (HQLA), specifically tokenized U.S. Treasuries and private credit, which have become the collateral backbone of the on-chain economy. The ecosystem is characterized by a "barbell" adoption curve. On one end, massive institutional incumbents like BlackRock, Franklin Templeton, Citi, and UBS are tokenizing sovereign debt and money market funds to streamline collateral management and settlement. On the other end, nimble fintech operators like Securitize, INX, and tZERO are building the secondary market infrastructure required to democratize access to historically illiquid assets like private equity, real estate, and music royalties.

However, significant friction remains. The secondary market for these assets is nascent, fragmented by jurisdiction, and plagued by a lack of unified liquidity. While issuance platforms have matured, the "Tokenized Secondary Liquidity Gap" remains the primary bottleneck to mass adoption. Regulatory frameworks are diverging, with Switzerland and the European Union offering clear, purpose-built regimes (DLT Act, DLT Pilot Regime), while the United States relies on a patchwork of enforcement actions and exemptions.

This report dissects these dynamics, offering deep dives into asset classes, platform mechanics, regulatory arbitrage, and the strategic implications for the future of capital markets.

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2. Market Sizing, Segmentation, and Growth Trajectory

In this context, to understand the magnitude of the shift toward tokenization, one must look beyond the hype cycles of crypto and focus on the fundamental metrics of assets under management (AUM) moving onto blockchain rails. The data from 2024 and 2025 paints a picture of exponential growth driven by institutional utility.

The Valuation Landscape: 2024–2025

The valuation of the RWA tokenization sector depends on how “asset” is defined. When strictly analyzing securities, excluding stablecoins like USDC or USDT which function as currency, the market has seen aggressive expansion.

By the close of 2024, the on-chain RWA market had established a baseline valuation of approximately $15 billion. This figure represented the early fruits of institutional pilots moving to production. However, the first half of 2025 witnessed a significant acceleration. By mid-2025, the market had expanded to over $24 billion, reflecting an annualized growth rate exceeding 85%. Alternate data aggregators, likely including a broader scope of private credit and off-chain assets with on-chain representations, value the market even higher, placing it at approximately $35.78 billion as of November 2025.

Ultimately, this growth is structurally different from previous crypto bull markets. It is not driven by retail speculation but by the high-interest-rate environment that persisted through 2024. Investors sought to move capital from non-yielding stablecoins into yield-bearing instruments. Consequently, the market is projected to breach the $50 billion mark by the end of 2025. Long-term forecasts remain staggering, with Citigroup and other analysts predicting the tokenization market could encompass between $4 trillion and $16 trillion by 2030, fundamentally rewriting the composition of global asset ownership.

Asset Class Segmentation

The composition of the market has shifted dramatically. In the early days of security tokens (2018–2020), the focus was on illiquid assets, that being real estate and private equity. In 2024–2025, the focus shifted to "High-Quality Liquid Assets" (HQLA).

Tokenized U.S. Treasuries: The New Collateral

This segment is the primary engine of recent growth. From a modest market capitalization of $775 million in early 2024, tokenized Treasuries surged to nearly $4 billion by early 2025. By October 2025, some datasets tracked the segment at $8.7 billion, representing a 251% year-on-year increase.

This vertical explosion is driven by the "carry trade" coming on-chain (earning rate spreads via Treasuries). With U.S. interest rates offering attractive yields, holding non-interest-bearing stablecoins became inefficient. Tokenized treasury funds allow investors to effectively hold "dollars that pay yield", combining the stability of cash with the returns of sovereign debt.

Private Credit: The Yield Engine

Private credit remains the largest nominal segment of the market, though its growth is steadier compared to the explosive nature of Treasuries. As of mid-2025, tokenized private credit accounted for approximately $14 billion to $18.7 billion of the total on-chain market. This sector allows originators to break down loan books into tokenized tranches, bypassing traditional banking intermediaries to source capital directly from DeFi protocols and institutional investors.

Real Estate and Equities

Real estate tokenization has grown but faces structural headwinds due to the heterogeneity of the underlying assets. Unlike a Treasury bond, which is fungible, every building is unique. Nevertheless, the segment, combined with commodities and other alternatives, contributes multiple billions of dollars to the total market cap. Tokenized equities have maintained a steady presence, particularly on platforms like INX, but have yet to see the "big bang" moment of a major public company issuing native digital shares.

The "Tokenization Cliff"

The industry is approaching what analysts describe as a "Tokenization Cliff", which is regarded as a positive point of inflection where adoption scales vertically due to network effects. The integration of these assets into collateral workflows (e.g., using a tokenized bond to satisfy margin requirements on a crypto exchange) is the catalyst for this cliff. We are currently in the early phase of this vertical ascent.

With that in mind, the segmentation in the table below highlights that the on-chain RWA market (~$30–35B) is heavily concentrated in yield-bearing, high-quality liquid assets, especially private credit and U.S. Treasuries, indicating that institutional adoption and collateral use cases are the dominant engines of growth.

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Tokenized Asset Classes – Market Snapshot (Late 2025)

Tokenized U.S. Treasuries: $8.7BYield-seeking capital leaving stablecoins. Collateral utility driving adoption.

Private Credit: $18.7BDemand for diversified yield. Disintermediation of banks.

Commodities: $2.9BInflation hedging. Ease of transfer vs. physical gold.

Total RWA Market: ~$30–$35BInstitutional adoption. Regulatory clarity in EU/Switzerland.

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3. The Dominance of High-Quality Liquid Assets (HQLA)

The most significant narrative of the 2024–2025 period is the dominance of tokenized treasury funds. This trend represents a "flight to quality" within the digital asset ecosystem. Unlike the speculative ICOs of 2017 or the NFT boom of 2021, current growth is fueled by boring, stable, institutional products.

BlackRock and the BUIDL Fund

The launch of the BlackRock USD Institutional Digital Liquidity Fund (BUIDL) was a watershed moment, signaling that the world's largest asset manager had moved beyond experimenting, to scaled commercial deployment.

Operational Mechanics

Issued on the Ethereum blockchain, BUIDL is a tokenized money market fund that invests in cash, U.S. Treasury bills, and repurchase agreements. The fund is tokenized by Securitize, a transfer agent and technology provider that acts as the bridge between the on-chain tokens and BlackRock's off-chain assets.

Growth and Adoption

Launched in March 2024, BUIDL attracted over $1.8 billion in assets within its first year. By mid-2025, the fund's Total Value Locked (TVL) exceeded $2.1 billion, with some metrics pushing as high as $2.9 billion. This rapid accumulation of assets allowed BUIDL to command approximately 42% of the tokenized treasury market share.

Utility Beyond Investment Exposure

The true innovation of BUIDL lies in its utility. It is not merely a passive investment vehicle.

Collateralization: The token is increasingly accepted as collateral by prime brokers (e.g., FalconX, Hidden Road) and derivatives exchanges (e.g., Deribit, Crypto.com). This allows traders to post BUIDL as margin, earning yield on their collateral while they trade, which is a significant capital efficiency improvement over posting non-yielding cash.
Liquidity Mechanics: In 2025, Securitize introduced daily dividend payouts and intra-day redemptions for BUIDL. Additionally, integrations with the Solana network were announced to reduce transaction costs and increase speed, highlighting a multi-chain strategy.

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Franklin Templeton’s First-Mover Advantage

While BlackRock captured the headlines in 2024, Franklin Templeton established the precedent years earlier with the Franklin OnChain U.S. Government Money Fund (FOBXX).

Structure and Innovation

FOBXX is the first U.S.-registered mutual fund to use a public blockchain to process transactions and record share ownership. Initially launched on Stellar due to its low costs, the fund expanded to Polygon, Avalanche, and Aptos by 2025, demonstrating a blockchain-agnostic approach.

Performance Metrics

As of late 2025, the fund holds over $420 million to $520 million in assets. While smaller than BUIDL, its significance lies in its "native" nature. The fund’s transfer agent maintains the official record of ownership on the blockchain, rather than the blockchain merely shadowing a traditional database.9 This makes FOBXX a genuine on-chain security record, not a cosmetic wrapper, and sets a precedent for how traditional funds can adopt DLT at the core of their operations.

Peer-to-Peer Capability

A critical innovation introduced in 2025 was the enabling of peer-to-peer transfers of BENJI tokens (the token representing shares of the fund) on the public blockchain. This moves the asset closer to the functionality of a medium of exchange, allowing investors to transfer value directly without an intermediary clearing layer, provided both wallets are whitelisted.

The Yield-Bearing Stablecoin Competitors

Alongside these registered funds, a "grey market" of yield-bearing instruments has emerged, targeting non-US investors or accredited US investors.

Ondo Finance: Bridges DeFi and TradFi with products like OUSG (which invests in BlackRock’s ETFs) and USDY (a yield-bearing note). Ondo focuses on DeFi composability, allowing its tokens to be used easily within decentralized exchanges and lending protocols. By 2025, they have cemented themselves as a leader in compliant lending.
Superstate: Founded by the creators of the Compound protocol, Superstate offers an SEC-registered short-term government bond fund. By 2025, it held over $517 million in TVL, targeting institutional crypto-natives who require a regulated place to park cash.
UBS "uMINT": In late 2024, UBS Asset Management launched its "UBS USD Money Market Investment Fund Token" (uMINT) on Ethereum. This product caters specifically to institutional demand in the Asia-Pacific region, leveraging UBS's distribution network.

Taken together, these products blur the line between stablecoins and money-market funds, creating yield-bearing alternatives to traditional stablecoins and putting competitive pressure on issuers that rely on a non-yielding cash model. For the broader RWA market, these instruments are important because they demonstrate investor appetite for tokenized cash equivalents that function like stablecoins in DeFi, while still being anchored in recognizable fixed-income structures.

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4. Real Estate Tokenization: Fragmentation and Opportunity

In this context, real estate tokenization promises to fractionalize high-value properties, reducing entry barriers for investors and increasing liquidity for owners. It is arguably the use case with the highest potential Total Addressable Market (TAM), yet it remains the most difficult to scale due to the heterogeneous nature of property and localized regulations.

Rather than coalescing into a single, unified market, real estate tokenization has evolved as a patchwork of models: different legal wrappers (SPVs, LLCs, DAO-LLCs), regulatory exemptions (Reg A+, Reg CF, private placements), blockchains (Ethereum sidechains, Algorand, Stellar), and target segments (institutional vs. retail). Two clusters have emerged as the most visible today:

Single-asset SPVs for “trophy” or institutional-grade properties; and
Retail-focused platforms offering fractional ownership in smaller residential assets.

Both models showcase the opportunity, but they also highlight the structural constraints that keep liquidity fragmented and scale limited.

The "Single-Asset" Model

The single-asset model involves creating a Special Purpose Vehicle (SPV), usually an LLC, that owns a single property. The shares of this SPV are then tokenized.

Case Study: St. Regis Aspen (Aspen Coin)

The St. Regis Aspen Resort remains the benchmark for this model. Approximately 19% of the equity in the luxury resort was tokenized as Aspen Coin.

Performance: By 2024–2025, these tokens were actively trading on secondary markets like tZERO. The project demonstrated the potential for "trophy assets" to find a global investor base.
Corporate Action: In a move demonstrating active management, the issuer, Aspen Digital Inc., initiated buyback programs in late 2024 to align the token price with the intrinsic asset value. This behavior mimics traditional public equity buybacks and signals maturity in the management of digital REITs.

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Retail-Focused Platforms and the LLC Model

Newer entrants focus on democratizing access for retail investors, often utilizing specific exemptions like Regulation A+ or Regulation CF in the US.

RealT

Model: RealT focuses on residential properties in the US Rust Belt (Detroit, Cleveland, Chicago). Each property is a separate LLC. Investors buy tokens representing a share in that LLC.
Technology: RealT utilizes the Gnosis Chain (a sidechain of Ethereum) and RMM (RealT Market Maker) to provide liquidity. Their innovation lies in the daily distribution of rental income directly to token holders' wallets, creating a tangible link between the asset and the yield.

Lofty AI

Model: Built on the Algorand blockchain, Lofty allows investment in US rental properties for as little as $50.
Legal Structure: It uses a DAO-LLC structure, where the governance of the property is handled by the token holders via a DAO. This sits in a regulatory grey area compared to fully registered securities but offers significant operational efficiency.

Realbricks

Differentiation: Realbricks competes by emphasizing a more conservative, SEC-regulated structure (Regulation A+), marketing itself as a "future-proof" alternative to the DAO model which may face regulatory scrutiny. They target the risk-averse retail investor who wants fractional real estate without the regulatory ambiguity.

Together, these platforms illustrate how similar real estate economics are being wrapped in very different legal and technical structures, contributing to market fragmentation across jurisdictions and investor segments.

Liquidity Challenges in Tokenized Real Estate

Despite the theoretical benefits, secondary market liquidity for real estate tokens remains orders of magnitude lower than for HQLA or crypto assets. Real estate is inherently illiquid; tokenization improves the mechanism of transfer but does not automatically create a buyer.

Data Insight: Platforms like CBRE Investment Management and Ares report that the traditional real estate secondary market (LP-led and GP-led transactions) reached record volumes in 2024 ($162 billion). However, the tokenized portion of this remains a small fraction. This suggests a massive growth opportunity if tokenized assets can tap into this existing institutional liquidity pool.

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5. Participative Financial Instruments: The Renaissance of Revenue Sharing

Beyond standard equity and debt, tokenization is reviving participative instruments like profit-sharing notes and royalty streams. These instruments are particularly well-suited for blockchain because smart contracts can automatically calculate and distribute variable payments based on underlying revenue or usage data.

At present, two clusters stand out:

Venture-style profit-sharing instruments that give investors exposure to a portfolio’s upside without traditional equity; and
IP- and royalty-based instruments, where future cash flows from music or other content are fractionalized and sold directly to investors and fans.

When combined, they illustrate how tokenization can re-open older corporate-finance tools in a more granular, programmable form.

The Republic Note: A Venture Capital ETF on Chain

Republic, a leading crowdfunding platform, issued the "Republic Note," a digital security that entitles holders to a share of the profits generated by Republic's investment portfolio and accelerator wings.

Mechanism: It is a profit-sharing token. When Republic realizes a successful exit from one of its portfolio companies (e.g., via IPO or acquisition), a portion of the proceeds is distributed to Note holders via stablecoins.
Strategic Value: Launched in mid-2024, the Note is designed to trade on secondary markets. It effectively democratizes access to Venture Capital, an asset class previously reserved for accredited investors and institutions. The token structure allows for fractional exposure to a diversified portfolio of hundreds of startups.

Music Royalties: The Uncorrelated Asset Class

Music royalties have proven to be an ideal candidate for tokenization. They offer yields that are uncorrelated with the stock market or interest rates, driven instead by streaming consumption patterns.

Royal

Founder: Founded by DJ 3LAU, Royal allows artists to sell a percentage of their streaming rights as tokens.
Mechanism: Fans buy these tokens and receive royalties as the songs are played on Spotify, Apple Music, etc. This creates a direct financial alignment between artist and fan, turning the fanbase into a marketing army.

Opulous

Innovation: Utilizing the Algorand blockchain, Opulous issues "Music Fungible Tokens" (MFTs). These are SEC-compliant security tokens that represent a share of the copyright and future revenue of a track.
DeFi Integration: Opulous integrates DeFi elements, allowing artists to borrow against projected future earnings, effectively creating a decentralized bank for musicians. They utilize AI to predict future royalties, pricing the risk of these loans.

JKBV and Catalog Tokenization

Beyond single tracks, the market is also seeing the tokenization of entire catalogs. In these structures, investors can treat music rights as an asset class similar to bonds, with predictable cash flows derived from decades of listening data and well-understood consumption patterns.

Relevance of Participative Instruments to RWA Markets

Participative financial instruments show that tokenization is not limited to wrapping existing equity and debt. It can reopen the design space of corporate finance around programmable, cash-flow-based sharing arrangements. Products like the Republic Note and tokenized music royalties:

Convert historically illiquid and relationship-driven revenue streams into transferable, divisible on-chain securities;
Align incentives among issuers, investors, and end-users, for example fans who are both consumers and economic participants; and
Demonstrate how smart contract automation can reduce the operational burden of tracking and paying variable cash flows across large and fragmented investor bases.

Overall, these experiments highlight a path for RWAs in which cash flows and participation rights, rather than only static ownership, become primary objects of tokenization and broaden both the range of tokenizable assets and the set of investors who can access them.

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6. Primary Issuance Platforms: The Infrastructure Layer

The "middleware" layer of the ecosystem is populated by platforms that handle the technical minting, compliance (KYC/AML), and lifecycle management of security tokens. In practice, these firms are the gatekeepers of the tokenized economy.

Leading Issuance Platforms

A small group of issuance platforms now dominates institutional activity in this segment.

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Leading Tokenization Platforms

Securitize
End-to-end issuance and transfer agent services. SEC-registered. Leader in institutional funds.
Clients: BlackRock, BUIDL, KKR, Hamilton Lane.
[Source: 6]

Tokeny
Compliance automation via the T-REX protocol (ERC-3643). Strong European focus.
Clients: Blockpit, various real estate issuers.
[Source: 20]

Polymath (Polymesh)
Developed the ERC-1400 standard. Created a dedicated blockchain (Polymesh) specifically for regulated assets.
Deployment: 200+ tokens.
[Source: 29]

Spydra
Asset tokenization with a focus on high-value assets like real estate and private equity.
Clients: Private funds.
[Source: 4]

Verta
Enterprise-grade infrastructure. Partnered with Nasdaq for digital asset integration.
Clients: Fidelity Investments, Nasdaq.
[Source: 30]

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These platforms define how issuers structure tokens, encode compliance, and connect to downstream trading and custody venues.

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Technical Standards and Interoperability

A critical development in 2024–2025 has been the coalescence around specific token standards.

ERC-3643 (T-REX): Championed by Tokeny, this standard embeds the compliance rules (KYC, whitelist checking) directly into the token's smart contract. This ensures that even if a token is sent to a non-compliant wallet peer-to-peer, the transfer will fail on-chain.
ERC-1400: A library of standards for security tokens allowing for more complex partitioning of assets (e.g., separating voting rights from dividend rights).
Integration with Legacy Systems: Platforms like Verta and Securitize are increasingly integrating with traditional transfer agents and custodians to allow "mirroring" of assets, in which the token and the traditional book-entry record coexist and reconcile in near-real-time.This hybrid model permits issuers to adopt DLT without abandoning existing market infrastructure and regulatory processes.

Why the infrastructure layer matters

By standardizing issuance, compliance, and integration with legacy systems, these platforms and token standards determine which assets can come on-chain, how easily they can move, and how safely institutions can participate. In practical terms, the infrastructure layer is what converts tokenization from one-off experiments into a repeatable process that can support large volumes of regulated assets across multiple jurisdictions and trading venues.

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7. The Secondary Market: The Liquidity Engine

The secondary market is the critical component for the success of digital securities. Without a venue to trade, tokenized assets remain illiquid, negating a primary value proposition of the technology. The landscape is sharply divided by jurisdiction, with distinct approaches in the US, Europe, and Switzerland.

United States: Alternative Trading Systems (ATS)

In the US, national securities exchanges (like NYSE or Nasdaq) have not yet fully integrated blockchain settlement. Consequently, digital securities trade on SEC-registered Alternative Trading Systems (ATS). These are regulated venues that match buyers and sellers but typically have lower volumes and visibility than national exchanges.

tZERO Group

Market Position: tZERO is a dominant player in terms of historical volume for digital securities in the US.
Regulatory Breakthrough: In late 2024, tZERO received approval as a Special Purpose Broker-Dealer (SPBD). This is a critical designation that allows them to custody digital asset securities, solving a major friction point where previously investors had to self-custody or use third-party qualified custodians.
Connectivity: They launched "tZERO Connect," an API allowing other broker-dealers to access their liquidity, attempting to build a networked liquidity pool rather than a siloed exchange.

INX Limited

Platform: INX operates "INX.One," a unified platform for trading both security tokens and cryptocurrencies. It is the first company to complete an SEC-registered IPO via a token (the INX Token).
Performance: In Q3 2024, INX reported operational improvements and continued listing of tokenized stocks (e.g., Nvidia, Tesla trackers) for non-US investors. Their strategy focuses on the "single pane of glass" for traders accessing both asset classes.

Oasis Pro Markets

Focus: Institutional infrastructure. Oasis Pro focuses on bridging DeFi and TradFi, allowing for the trading of tokenized private funds. They are less retail-focused than tZERO or INX and act more as an infrastructure pipe for investment banks.

Overall, the current U.S. landscape reflects a regulation-first approach to secondary markets for tokenized securities. Trading is concentrated on ATS platforms and SPBD-enabled intermediaries, which limits market depth but ensures that custody, settlement, and investor protection frameworks remain aligned with traditional securities rules. In effect, the U.S. is prioritizing controlled experimentation over rapid, retail-led growth.

Europe: The DLT Pilot Regime

The European Union has taken a progressive approach with the DLT Pilot Regime, launched in 2023. This regulatory sandbox allows market infrastructure operators to use DLT for trading and settlement, temporarily exempting them from certain provisions of CSDR (Central Securities Depositories Regulation) regarding central recording.

21X (Frankfurt)

Milestone: 21X became the first fully regulated DLT Trading and Settlement System (DLT TSS) under the EU regime.
Activity: In 2025, 21X opened its primary market with tokenized notes on UBS money market funds. This platform allows for smart contract-based issuance and settlement without the need for a separate Central Securities Depository (CSD) or clearing house, significantly reducing costs.

Switzerland: The Mature Haven

Switzerland offers the most advanced regulatory framework, the "DLT Act," which allows fully regulated digital exchanges to operate with legal certainty.

SIX Digital Exchange (SDX)

Overview: The digital arm of the main Swiss stock exchange (SIX). It operates a fully regulated Central Securities Depository (CSD) on DLT.
Volume: By mid-2024, SDX surpassed 1 billion CHF in digital asset issuance. This included digital bonds from the World Bank, UBS, and the Canton of Zurich.
Atomic Settlement: SDX facilitates "atomic settlement" using wholesale Central Bank Digital Currency (wCBDC) provided by the Swiss National Bank (SNB). This eliminates counterparty risk, as the asset and the cash move simultaneously or not at all.

BX Digital:

Status: A subsidiary of Boerse Stuttgart, BX Digital received its license from FINMA in 2025 to operate a DLT Trading Facility. Unlike SDX, which focuses on permissioned institutional flows, BX Digital aims to support more accessible tokenized securities trading, utilizing public blockchains (initially Ethereum) to tap into broader liquidity.

When analysed in conjunction, the United States, European Union, and Switzerland illustrate three distinct approaches to secondary markets for digital securities. The U.S. layers tokenization onto existing ATS and broker-dealer structures, preserving regulatory continuity but fragmenting liquidity. The EU is testing purpose-built DLT market infrastructure through the DLT Pilot Regime, while Switzerland has already granted full legal recognition to tokenized securities via platforms such as SDX, enabling natively digital assets to trade on regulated venues.

The Liquidity Gap

Despite these platforms, a "Liquidity Paradox" persists. While issuance is booming ($50B projected in 2025), secondary trading volumes on ATSs like tZERO and INX remain comparatively low, often in the millions per month rather than billions.

The core issue is a mismatch between issuance technology (which is mature) and market maker participation. Traditional high-frequency trading (HFT) firms are hesitant to connect to blockchain-based ATSs due to latency issues and the fragmented nature of liquidity. Until major liquidity providers enter the space, secondary markets will function more as "call markets" (periodic auctions) rather than continuous liquid markets, which constrains price discovery and reduces the appeal of tokenization for trading-oriented investors.

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8. Institutional Strategies and Adoption

The narrative of "banks vs. crypto" has dissolved. It has been replaced by "banks using crypto rails" to optimize their own operations. In practice, this shift is visible in bank-led deployments of tokenized deposits, digital bonds, and internal settlement networks designed to improve liquidity management, collateral efficiency, and cross-border settlement. At the same time, the strategic focus is moving from isolated private networks toward interoperability, so that these systems can communicate with public blockchains and with each other. This section reviews the leading institutional initiatives and the interoperability layer that is increasingly becoming the key enabler of scale.

Banking Giants

Citi Token Services: Citi launched a permissioned blockchain network to tokenize customer deposits, allowing for 24/7 liquidity management and cross-border payments. In 2025, this expanded to include Euro integration and pre-trade/post-trade collateral management. Citi is effectively building an internal "intranet of value" that interoperates with the wider world.
J.P. Morgan (Kinexys): Formerly known as Onyx, the rebrand to Kinexys in late 2024 signaled a broader push into tokenized assets. Their platform has settled over $1.5 trillion in intraday repo transactions. The platform is now expanding into renewable energy and carbon credit tokenization, creating new asset classes for their institutional clients.
UBS Tokenize: UBS has been aggressively issuing digital bonds. In 2024 and 2025, they executed transactions for the World Bank and floated their own digital structured notes. They successfully tested the Chainlink Digital Transfer Agent (DTA) standard to ensure their private tokenized assets could be read and interacted with by other systems.
Societe Generale-FORGE: While known for their EUR CoinVertible stablecoin, SG-FORGE structures it as a security (bond) on the Ethereum blockchain. In 2025, they expanded to the Solana blockchain and integrated with global custodians like BNY Mellon, prioritizing speed and low cost for their settlement layer.

Interoperability: The Holy Grail

In this context, a key theme in 2025 is the move away from "walled gardens" (private blockchains that can't talk to each other).

Chainlink (CCIP): Institutions are utilizing Chainlink’s Cross-Chain Interoperability Protocol (CCIP) to allow assets to move between private bank chains and public chains like Ethereum. Grayscale identifies Chainlink as the "connective tissue" essential for the tokenization economy.
Swift: The global messaging giant is actively testing mechanisms to allow existing banking systems to transact with varied blockchains, ensuring that tokenized assets can flow through the global financial arteries without banks needing to rip and replace their existing messaging infrastructure.

Collectively, these initiatives show that institutional adoption of tokenization is no longer experimental. It is increasingly focused on operational efficiency, controlled interoperability, and integration with existing financial infrastructure, rather than on wholesale disruption of the banking system.

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9. Global Regulatory Landscape: A Deep Dive

As tokenization matures, regulatory clarity has become the primary determinant of market speed, structure, and location. The global landscape remains fragmented, with jurisdictions like Switzerland and the UAE implementing purpose-built legal frameworks, while the U.S. continues to adapt existing securities laws to digital assets. This divergence creates significant opportunities for regulatory arbitrage, as issuers and platforms gravitate toward regimes that offer legal certainty, operational efficiency, and scalable market infrastructure.

Switzerland: The "Gold Standard" of Digital Law

Switzerland has established itself as the premier jurisdiction for digital securities, driven by a legislative approach that amends existing civil codes rather than creating a separate "crypto law."

The DLT Act & Ledger-Based Securities: Entering into full force in 2021, the "Federal Act on the Adaptation of Federal Law to Developments in Distributed Ledger Technology" (DLT Act) introduced the concept of "Ledger-Based Securities" (Art. 973d of the Code of Obligations). This provides digital tokens with the same legal standing as traditional certificated securities. Crucially, it grants creditors the "power of disposal" over the asset directly via the blockchain, excluding the debtor (issuer) from control, which is essential for bankruptcy remoteness.
The DLT Trading Facility License: A key innovation of the Swiss regime is the DLT Trading Facility license (FinMIA Art. 73a). Unlike traditional finance, where exchanges (trading) and Central Securities Depositories (settlement) must be separate legal entities, this license allows a single entity to provide trading, custody, and settlement services for DLT securities. This vertical integration significantly lowers costs and complexity.

BX Digital: In 2025, BX Digital (part of Boerse Stuttgart) became the first entity to receive a "Small DLT Trading Facility" license from FINMA. This allows them to trade and settle tokenized securities (stocks, bonds) for retail clients using a public blockchain (Ethereum), a major milestone for retail adoption.
SDX (SIX Digital Exchange): Operating at the institutional level, SDX holds both a Stock Exchange and a CSD license, allowing it to settle transactions atomically using wholesale Central Bank Digital Currency (wCBDC) from the Swiss National Bank.

Staking and Custody: In December 2023, FINMA issued guidance clarifying that crypto assets held by custodians can be kept off-balance sheet (segregated) if they are held on individual addresses or otherwise clearly attributable to the client. This protects client assets in the event of a custodian's bankruptcy.

European Union: The Pilot Regime Sandbox

The EU has taken a cautious, experimental approach via the DLT Pilot Regime, which allows market operators to request exemptions from existing regulations (MiFID II and CSDR) to test DLT infrastructure.

The DLT TSS Innovation: The Pilot Regime created a new license category: the DLT Trading and Settlement System (DLT TSS). Similar to the Swiss model, this allows one operator to handle both trading and settlement, bypassing the need for a separate CSD.
Authorized Entities:

21X (Germany): In late 2024, 21X became the first fully regulated DLT TSS in Europe. Based in Frankfurt, it allows for the smart contract-based issuance and settlement of tokenized stocks, bonds, and funds.
Axiology (Lithuania) & CSD Prague: Other authorized entities include Axiology (operating a DLT Settlement System) and CSD Prague.

Threshold Limitations: The regime imposes strict volume limits to contain risk. Market capitalization for shares is capped at €500 million, and bonds at €1 billion. The aggregate value of all assets on a DLT platform cannot exceed €6 billion (with a transition requirement triggered at €9 billion). These limits have been criticized for restricting institutional participation, leading ESMA to suggest recalibrating thresholds in its 2025 report.

United States: The Patchwork of Exemptions

The U.S. regulatory environment remains the most complex, characterized by enforcement actions and a lack of bespoke legislation. However, 2025 saw significant shifts in how broker-dealers can interact with these assets.

Special Purpose Broker-Dealers (SPBD): In 2020, the SEC introduced the SPBD framework, allowing registered broker-dealers to custody digital asset securities. tZERO received this approval in late 2024, allowing it to custody client assets directly: a critical step for operating a seamless trading venue.
The "May 2025 FAQ" Shift: In May 2025, the SEC Division of Trading and Markets issued new guidance (FAQs) effectively easing the strict custody requirements of the 2019 Joint Staff Statement. The FAQs clarified that broker-dealers can establish "control" of uncertificated crypto asset securities (under Rule 15c3-3) without necessarily needing the bespoke SPBD status, provided the assets are held at a qualifying control location. This "roll back" of stricter criteria is expected to lower barriers for traditional broker-dealers to enter the space.
The Transfer Agent Model: Unlike Europe, where a CSD is central, the U.S. tokenization market relies heavily on SEC-registered Transfer Agents (e.g., Securitize, Franklin Templeton). These agents maintain the "Golden Record" of ownership. The blockchain records are often considered a "courtesy copy" or secondary record, though firms like Franklin Templeton have received no-action relief to treat the blockchain as the primary record for their money market funds.

United Arab Emirates (UAE): The Three-Peak Jurisdictional Model

The UAE has established itself as a global crypto hub by offering a "choice of regime" through its three distinct regulatory jurisdictions: ADGM, DIFC, and VARA.

ADGM (Abu Dhabi Global Market): Regulated by the Financial Services Regulatory Authority (FSRA), ADGM is known for its institutional-grade "Digital Asset Regulatory Framework" (updated June 2025). It treats virtual assets similarly to traditional financial instruments and has introduced specific guidance on staking, requiring firms to disclose risks and ensuring client assets are not used for staking without explicit consent.
DIFC (Dubai International Financial Centre): Regulated by the Dubai Financial Services Authority (DFSA), the DIFC enacted its "Digital Assets Law" (DIFC Law No. 2) in 2024. It creates a legal definition for "Digital Assets" as property. The DFSA specifically recognizes "Security Tokens" (investment tokens) and has a prohibition on privacy tokens and algorithmic stablecoins. It focuses heavily on ensuring issuers provide a "Key Information Document" similar to a prospectus.
VARA (Dubai Mainland): The Virtual Assets Regulatory Authority (VARA) regulates the mainland and free zones (excluding DIFC/ADGM). VARA has released specific rulebooks for Real Estate Tokenization, classifying them as "Asset-Referenced Virtual Assets" (ARVA). These rules require the real estate to be held in an SPV, mandatory audits, and a comprehensive whitepaper detailing the rights of token holders. This creates a clear, legal pathway for fractionalized property investment that is absent in many Western jurisdictions.
SCA (Federal): The federal regulator (SCA) handles the wider UAE. In 2025, it opened consultation on a new "Security Token Regime" to harmonize rules onshore, ensuring that security tokens are traded only on licensed exchanges (like the Abu Dhabi Securities Exchange or DFM).

Comparative Regulatory Frameworks (2025)

Switzerland (FINMA)
Legal Basis: DLT Act (Civil Code Amendment)
Trading & Settlement: Combined License (DLT Trading Facility)
Retail Access: Permitted (e.g., BX Digital)
Blockchain: Public or Private
Key Innovation: "Ledger-based Securities" (Civil Law)

EU (ESMA/Pilot Regime)
Legal Basis: DLT Pilot Regime (Sandbox)
Trading & Settlement: Combined License (DLT TSS)
Retail Access: Permitted but capped by volume
Blockchain: Public or Private
Key Innovation: Unified Trading/Settlement Entity

USA (SEC)
Legal Basis: Securities Act 1933 (Exemptions)
Trading & Settlement: Separated (ATS → Transfer Agent)
Retail Access: Restricted (mostly Accredited)
Blockchain: Primarily Private/Permissioned
Key Innovation: Transfer Agent as Record Keeper

UAE (ADGM/DIFC/VARA)
Legal Basis: Bespoke Digital Asset Laws
Trading & Settlement: Combined or Separated (Varies by Zone)
Retail Access: Permitted with strict disclosure
Blockchain: Public or Private
Key Innovation: Specific Real Estate Token Rules (VARA)

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10. Conclusion and Strategic Outlook

The market for security tokens and real-world asset tokenization has successfully crossed the "trough of disillusionment" phase; post-hype correction and consolidation. It is no longer a speculative future but a growing component of the shadow banking and institutional finance sectors.

Key Conclusions

Yield is King: The explosion of tokenized Treasuries proves that utility (yield + collateral) drives adoption, not novelty.
Infrastructure is Ready: With platforms like Securitize, tZERO, and SDX fully operational, the technological barriers to entry have been removed.
Liquidity is the Final Boss: The secondary market remains thin. The next phase of growth (2026–2030) will depend on connecting these disparate liquidity pools via interoperability protocols (CCIP) and attracting high-frequency market makers.

With a $50 billion market on the horizon for 2025, led by government debt and private credit, the infrastructure is being laid for a multi-trillion dollar transformation by 2030. Ultimately, the winners in this phase are the regulated infrastructure providers who can navigate the complex web of global compliance while offering the speed of DeFi.

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11. Appendix: Key Data Tables

Comparative Analysis of Major Secondary Market Platforms

tZERO (USA)
Regulatory Status: SEC-registered ATS / SPBD
Primary Asset Types: Real Estate, Private Equity, Crypto Equities
Blockchain Tech: Private/Public Mix

INX.One (USA)
Regulatory Status: SEC-registered ATS / Broker-Dealer
Primary Asset Types: Tokenized Stocks, Security Tokens, Cryptocurrencies
Blockchain Tech: Ethereum

SIX Digital Exchange (SDX) (Switzerland)
Regulatory Status: FINMA-regulated Exchange & CSD
Primary Asset Types: Digital Bonds, Native Digital Equities
Blockchain Tech: Corda (Permissioned)

BX Digital (Switzerland)
Regulatory Status: FINMA-regulated DLT Trading Facility
Primary Asset Types: Tokenized Securities (SME focus)
Blockchain Tech: Ethereum (Public)

21X (Germany/EU)
Regulatory Status: DLT Trading & Settlement System (TSS)
Primary Asset Types: Funds, Bonds, Equities (under Pilot Regime)
Blockchain Tech: Polygon (Public)

Securitize Markets (USA)
Regulatory Status: SEC-registered ATS
Primary Asset Types: Tokenized Funds, Yield Products
Blockchain Tech: Ethereum, Avalanche, Polygon

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Top Tokenized Treasury/Bond Products (Estimated AUM 2025)

BUIDL (BlackRock)
Technology Partner: Securitize
Estimated AUM: ~$2.1B+
Key Feature: Daily dividends. Integrates with USDC liquidity.

FOBXX (Franklin Templeton)
Technology Partner: Internal (Benji)
Estimated AUM: ~$420M–$520M
Key Feature: Multi-chain (Stellar, Polygon, Aptos, Avax)

OUSG/USDY (Ondo Finance)
Technology Partner: Ondo Protocol
Estimated AUM: ~$600M+
Key Feature: DeFi composability focus

Hashnote (Hashnote)
Technology Partner: Laser Digital
Estimated AUM: ~$500M+
Key Feature: Institutional short-duration yield

OpenEden (OpenEden)
Technology Partner: -
Estimated AUM: ~$150M+
Key Feature: TBILL vault focusing on Asia/Europe

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Real World Asset Tokenization, Digital Securities, and Participative Financial Instruments