2026.09.11
Recently, JunHe assisted a leading company (the Client) in successfully completing a structured note issuance with gold as the underlying asset. They also assisted the Client in successfully trading the tokenized product of the linked notes on a compliant RWA exchange on the Singapore blockchain. As the market's first tokenized RWA of structured notes with physical gold as the underlying asset, this project successfully integrates traditional financial products, distributed ledger technology (DLT) and the market-favored gold. It allows Web3 investors to enjoy the benefits brought by gold and serves as a benchmark case in RWA innovation in Asia. It fully demonstrates JunHe's comprehensive legal service capabilities in financial products, real-world asset (RWA) tokenization and cross-border regulatory compliance.
In terms of product structure, this project breaks the conventions of fixed income note RWAs in the market by introducing both physical gold and digital gold as dual underlying assets. The returns are directly linked to the increase in gold prices, while also granting investors the right to redeem the notes in the form of physical gold. Leveraging its extensive experience in the field of structured products, JunHe tailored a product structure solution for the Client that accurately reflects the fluctuations in gold prices and supports physical gold redemption.
In terms of the transaction’s architecture, the project involved complex coordination among multiple roles including the note issuer, the gold trustee, the gold procurement agent, the gold custodian and the token issuer. The responsibilities and obligations of all the parties were interlinked throughout the token issuance, circulation and redemption process. JunHe designed the transaction documents to clearly define the rights, responsibilities and operational processes of each participant. They created a legal closed loop covering the entire product process including token investment, gold procurement, gold custody, gold disposal and token redemption.
Based on a thorough understanding of the regulatory requirements and our extensive experience in tokenized RWA projects, we provided the Client with a practical implementation plan that successfully balanced product compliance with commercial feasibility.
This project fully demonstrates the effective combination of traditional structured products, distributed ledger technology (DLT) and market investment hotspots. It provides a meaningful reference model for the digital innovation of traditional financial products. The project also holds great significance in terms of product structure innovation, compliance implementation and investor acceptance, further highlighting JunHe's outstanding capabilities in financial products, regulatory compliance and financial technology.
QIAO, Zheyuan (Jacqueline) was the lead partner in this project.
