全球RWA监管政策解析：多元探索中的合规路径

Core Insights - The rapid development of the RWA (Real World Asset tokenization) market is prompting global regulatory bodies to construct regulatory frameworks at varying paces and approaches [1] Group 1: Regulatory Approaches by Region - United States: The U.S. exhibits a multi-regulatory approach, with the Federal Reserve's Waller indicating a shift from caution to rational acceptance of tokenization technology. The SEC's cryptocurrency task force is engaging with the industry on "traditional asset tokenization," indicating an active construction of the regulatory framework [3] - Hong Kong: The Hong Kong Securities and Futures Commission adopts a proactive regulatory stance, with securities-type tokens regulated by the SEC and commodity-type tokens by the CFTC. Licensed virtual asset trading platforms are allowed to serve retail investors, with strict risk assessment and investor suitability management requirements [3][5] - Singapore: The Monetary Authority of Singapore (MAS) adheres to the "same risk, same regulation" principle, emphasizing testing innovations in a controlled environment through mechanisms like regulatory sandboxes [5] - European Union: The EU is establishing a comprehensive regulatory framework through MiCA (Markets in Crypto-Assets), providing a clear compliance path for RWA projects, albeit with stringent compliance requirements that raise market entry barriers [5][6] - United Arab Emirates: The UAE is actively creating a global digital asset hub with a multi-layered regulatory framework to attract global RWA projects, emphasizing a friendly regulatory environment [8][9] Group 2: Common Regulatory Themes - There is a growing consensus among jurisdictions despite differing regulatory paths, reflecting various balances between financial innovation, risk prevention, and market development [8] - The UAE's VARA (Virtual Assets Regulatory Authority) is responsible for specialized virtual asset regulation, while the Abu Dhabi Global Market (ADGM) implements inclusive regulatory policies, focusing on aligning with international standards while considering local characteristics [9] - Emphasis on substance over form in regulation, with a risk-based approach to regulatory measures and enhanced investor protection through information disclosure and suitability requirements [9][10]