Sections 02–03
Global: regulation, rails and cross-border capital
Licensed product frameworks, central-bank-proven settlement layers, and hundreds of billions per quarter of cross-border institutional capital already moving — against screening regimes that review essentially every sovereign acquisition.
US$5,116.3b
Stock of cross-border investment, sampled markets
National statistics agencies, 31 December 2025
US$8.9b
Gulf sovereign FDI, Oct–Dec 2024 quarter
Second-largest source, up from US$0.1b
US$163b
Renewable energy project pipeline
Five-year estimate, sampled markets
US$200b
Regional private credit stock
About half in real estate
Regulation
Licensed digital asset frameworks
Across the major markets, digital asset legislation progressed from exposure draft in late 2025 to enactment through the first half of 2026. The common architecture creates two new licensed financial products — regulated digital asset platforms and tokenised custody platforms — both requiring an operating licence and subject to custody standards, settlement requirements, disclosure and dispute-resolution obligations, with the securities regulator as primary supervisor.
Transition periods run roughly 18 months (12 months to commencement plus 6 months to apply). Existing operators dealing in financial products must lodge a complete licence application within the transition window to retain no-action protection. Guidance is under review in most jurisdictions; the reforms confirm public permissionless networks are not themselves financial products, and class relief is emerging for intermediaries distributing licensed-issuer stablecoins.
AML / CTF
Baseline obligations
- Exchange registration with AML/CTF authorities is the baseline; renewal every three years.
- The Travel Rule is in force across FATF-aligned jurisdictions from 31 March 2026.
- Cross-border transfers require international funds transfer reporting within 10 business days.
- Threshold transaction reports apply to cash transactions over US$10,000.
Central bank pilots
Wholesale CBDC programmes, final reports 2026
Twenty use cases — 12 live pilots with real money and assets, 8 proofs-of-concept — ran from August 2025 to February 2026 across fixed income, managed funds, repos, structured products, private markets, carbon credits and trade payables. They achieved a world first: issuing a pilot wholesale CBDC onto both public and private distributed ledgers.
Settlement used central bank reserve balances, pilot wCBDC, tokenised bank deposits and regulated stablecoins across five platforms spanning public networks, permissioned enterprise chains and privacy-preserving Layer-2s. The next phase is a structured regulatory sandbox taking industry from experimentation to commercialisation.
Headline estimate
US$24b
Annual gain from full-scale tokenisation across the sampled markets — though researchers note only ~US$1 billion would be realised by 2030 on the current trajectory.
Existing players
Who is already on the field
| Player | What they are | Why it matters |
|---|---|---|
| Listed crypto fund managers | Exchange-listed digital asset managers | Several wound up RWA funds in 2025 after failing to attract investment beyond their own seed commitment. Demand must precede launch. |
| Formally verified networks | Academically validated public chains with participant KYC | KYC/AML for all participants; first public chains to host a wholesale CBDC; multi-billion on-chain assets; consolidating registry providers. |
| Registry and unlisted-equity platforms | Private-company tokenisation and registry services | Registry services for unlisted securities worth over US$1 billion. Increasingly acquired by settlement networks. |
| Privacy-preserving Layer-2s | Institutional zero-knowledge settlement venues | Executed the first live repos using tokenised government bonds and live wholesale CBDC in central bank pilots. |
| Institutional liquidity providers | Trading, liquidity and custody desks | Fireblocks founding partners; Lloyd's-insured MPC custody; delivered the first bank-issued stablecoin transactions for corporate clients. |
| Digital asset managers | Regulated fund managers issuing tokenised funds | Partnered with registry and settlement networks on tokenised fund launches. |
| Global systemically important banks | Bank-issued stablecoins and deposit tokens | First live bank stablecoin payments from 2022; world-first intra-bank cross-border stablecoin transactions on public L1s. All central bank pilot participants. |
| Fractional property platforms | Retail fractional residential property (trust-based) | Units from ~US$50 — proof of retail appetite for fractionalisation, with limited liquidity. |
Capital base
Pension capital and the investable asset stack
Pension capital
US$58 trillion, with headroom
Asset base
What can be tokenised
Screening
Foreign investment: the hard constraint
- Substantial interest is typically 20%+ (subject to monetary threshold); direct interest is 10%+ for national-security businesses, land and media, at any value.
- 2026 thresholds vary by treaty status: non-treaty US$347m; treaty partners US$1.498bn; sensitive sectors and agribusiness US$73m; residential US$0; foreign government investors US$0.
- New mandatory merger control regimes commenced across several markets on 1 January 2026.
- Multiple jurisdictions now restrict foreign purchases of established dwellings for defined periods.
- Key friction: sovereign wealth funds face a US$0 threshold, so essentially all SWF acquisitions are screened. Tokenising ownership does not remove this and can complicate beneficial-ownership tracing.
| Source | Oct–Dec 2024 FDI |
|---|---|
| United States | $14.2 billion |
| Saudi Arabia | $8.9 billion (from $0.1b prior quarter) |
| Canada | $5.7 billion |
| Singapore | $4.0 billion |
| UAE | $1.8 billion |
Finance and insurance overtook commercial real estate as the leading sector. Singapore and Canadian capital injected ~US$4.1 billion into prime office towers in 2025, attracted by AAA sovereign ratings and tax-efficient trust structures. GCC sovereign wealth funds manage ~US$5 trillion, projected to ~US$7.6 trillion by 2030.
