2026.07.06
JunHe recently assisted a leading consumer credit fintech company (the client) in completing the tokenised issuance of interests in a sub-fund of its Hong Kong open-ended fund company (OFC). By combining a traditional private credit fund with distributed ledger technology (DLT), this real-world asset (RWA) project is an important milestone in the digital transformation of Hong Kong’s asset management industry and the development of innovative RWA applications. As one of the more notable successful placements in Asia this year involving the tokenisation of non-standardised underlying assets, the project sets a precedent in terms of product structuring, regulatory implementation and investor uptake. It is a benchmark transaction for the tokenisation of non-standardised assets in Asia and further demonstrates JunHe’s integrated legal capabilities across financial products, asset management regulation and fintech.
The product involved in the project had been authorised by the Hong Kong Securities and Futures Commission (SFC), making it a compliant RWA project developed within its regulatory framework. Under the current regulations, the project effectively aligns the arrangements for holding fund interests with an on-chain tokenisation mechanism, demonstrating Hong Kong’s regulatory openness and capacity for innovation as an international asset management centre seeking to integrate traditional finance with digital technology.
Acting as the legal counsel to the client in this project, JunHe provided comprehensive legal support across the RWA offering. JunHe’s services included the overall design and optimisation of the legal structure for the tokenisation, drafting and revising the tokenisation provisions in the fund documents, reviewing the compliance of the technical arrangements, and assisting the client in communicating with the SFC on the tokenisation-related matters. JunHe developed legal solutions for the various participants that complied with Hong Kong’s current regulations on key issues such as establishing the legal title to the underlying assets, ensuring the effective alignment between the on-chain interests and the off-chain rights and obligations, and structuring the fund governance arrangements. This ensured the project remained compliant throughout the regulatory review process.
Following its launch, the offering received a positive market response, with strong subscription demand totaling tens of millions of U.S. dollars. Built on a robust compliance foundation, the tokenisation project demonstrates the strong market demand for high-quality tokenised assets within the SFC’s regulatory framework. It also reflects investors’ confidence in the client’s product capabilities, asset selection expertise and its on-chain issuance model. As well as achieving significant commercial results, this is an industry-leading precedent for broader institutional participation in Hong Kong’s RWA market and the tokenisation of fund interests.
This offering demonstrates how a traditional fund structure can be effectively integrated with DLT within a compliant regulatory framework. It provides a valuable practical model for the Hong Kong asset management industry as it advances RWA, tokenization and wider digital innovation. JunHe will closely monitor regulatory developments in Hong Kong relating to virtual assets, RWA and tokenisation, and continue to provide clients with professional legal support for innovative projects in these areas.
This project was led by JunHe partners QIAO, Zheyuan (Jacqueline) and LIN, Jiayu (Paul).
