RWA Under Strict Regulation: CICC Hong Kong Takes Emergency Action, Ant Group and JD.com on High Alert, Is the Compliance Window Opening?

Written by: Liang Yu

Edited by: Zhao Yidan

In February 2026, Caixin.com published a major report titled “Strict Regulation of Offshore RWA,” revealing the latest stance of regulatory authorities on cross-border issuance of real-world assets (RWA). The report pointed out that “strict offshore regulation” is the overarching tone established in the “Notice on Further Preventing and Disposing of Virtual Currency Trading and Speculation Risks” (also known as “Document No. 42”) jointly issued by nine departments in 2021. However, this tone does not mean a simple “one-size-fits-all” approach.

According to informed regulatory sources, Hong Kong, as one of the offshore issuance locations for RWA, projects based on local assets are not within the scope of the “Document No. 42” regulation and are not under the jurisdiction of domestic regulators. For RWA issued based on domestic assets abroad, the regulatory logic has shifted from “completely prohibited” to “not entirely disallowed,” but such activities must be strictly supervised by the China Securities Regulatory Commission’s (CSRC) Institutional Department. The report emphasizes that there is no “encouragement” implied here; it should not be interpreted as “promoting development” or “rapid expansion.” The core remains “strict regulation.”

Just before and after the release of the Caixin report, market rumors emerged: China International Capital Corporation (CICC) Hong Kong team has been engaging with major public blockchains and exchanges to explore business cooperation. Tech giants like Ant Group and JD.com also expressed high concern over policy changes. These actions have sparked market discussion: under the “strict regulation” tone, why are leading institutions accelerating their布局? What space for compliant RWA innovation has policy actually left?

This article takes the Caixin report as a starting point, combined with the policy framework of Document No. 42, recent implementation cases, and institutional movements, to penetrate the surface meaning of “strict regulation” and restore a true picture of the new RWA regulatory landscape.

1. Policy Origins: Where exactly is Document No. 42 “Strict”?

To understand the current policy environment for RWA markets, we must go back to September 2021, when the People’s Bank of China (PBOC) and ten other departments jointly issued the “Notice on Further Preventing and Disposing of Virtual Currency Trading and Speculation Risks.” This document laid the foundation for China’s stance on virtual assets, and its core statements remain the fundamental guidelines for market participants.

According to the notice, virtual currencies do not have the same legal status as fiat currency. Cryptocurrencies like Bitcoin, Ethereum, and Tether lack legal tender status and cannot circulate as currency in the market. More critically, the notice explicitly states that “activities related to virtual currencies are illegal financial activities”—including legal currency and virtual currency exchange services, virtual currency-to-virtual currency exchanges, information intermediary and pricing services for virtual currency trading, token issuance financing, and derivatives trading—these are strictly prohibited and must be resolutely shut down.

This means any fundraising activities within China that use virtual currencies as a medium are on the red line. Similarly, offshore virtual currency exchanges providing services to domestic residents via the internet are also considered illegal financial activities. This clause effectively blocks domestic entities from bypassing regulations to participate in virtual currency trading offshore.

However, Document No. 42’s regulatory focus is on “virtual currencies” rather than “tokenized assets.” The two are fundamentally different: virtual currencies lack physical backing, and their prices are entirely driven by speculation; whereas RWA (Real-World Asset Tokenization) involves expressing ownership of real-world assets like bonds, loans, or real estate in digital form on the blockchain. This distinction sets the stage for subsequent policy refinement.

According to Caixin’s sources familiar with regulators, the “strict offshore regulation” in Document No. 42 mainly targets RWA issued abroad based on domestic assets. RWA backed by Hong Kong assets are outside the scope of Document No. 42 and are not under the jurisdiction of domestic regulators. This means tokenized issuance of Hong Kong-based assets enjoys a relatively independent policy space.

However, regulators emphasize: for outbound RWA based on domestic assets, “not all are prohibited now,” but they must undergo strict supervision by the CSRC’s Institutional Department. Moreover, “there is no ‘encouragement’ here; it should not be interpreted as ‘promoting development’ or ‘rapid expansion,’ but as ‘strict regulation.’”

From this, we can outline a clear layered regulatory framework:

• Red Zone (Domestic): Domestic institutions and individuals are strictly prohibited from any form of virtual currency-related RWA issuance or trading within China.

• Strict Control Zone (Outbound Domestic Assets): RWA based on domestic securities, funds, or loans issued abroad (including Hong Kong) must undergo transparent supervision by the CSRC, with high compliance costs and strict approval thresholds.

• Exception Zone (Hong Kong Assets): RWA issuance based on Hong Kong local assets is overseen by the Hong Kong Securities and Futures Commission (SFC) according to its regulatory framework, not directly subject to Document No. 42.

This layered framework clarifies the direction for compliant RWA innovation.

2. Compliance Window: The “Breakthrough” Path for Asset-Backed Securities Tokens

If Document No. 42 defines “what not to do,” then the CSRC’s supporting guidelines gradually clarify “what can be done.”

In November 2023, the Hong Kong SFC issued the “Circular on Intermediaries Engaged in Activities Related to Tokenized Securities” and the “Circular on Recognized Investment Products for Tokenization,” systematically elaborating the regulatory stance on tokenized securities. The circular states that tokenized securities are essentially traditional securities packaged via tokenization, and existing securities laws and regulations continue to apply.

This statement has profound implications: it means that as long as the underlying assets are compliant securities, their tokenization does not alter their security nature nor automatically trigger additional regulatory bans. The key is to ensure that the tokenization process does not introduce new risks—including ownership record risks, technological risks, cybersecurity risks, etc.

Under this framework, asset-backed securities tokens (ABSTs) supported by domestic cash flows have become the most feasible compliant path. The operation logic involves structuring high-quality domestic assets (such as supply chain receivables, infrastructure revenue rights, consumer credit portfolios) through special purpose vehicles (SPVs), and issuing digital securities in offshore markets (mainly Hong Kong).

The compliance points for this model include: first, the underlying assets must be genuine, legal, and transparent; second, the issuer must be licensed or cooperate with licensed institutions; third, the tokenization arrangement must undergo third-party audits to ensure smart contract security and integrity; fourth, cross-border fund flows must be channeled through qualified domestic institutions (QDIIs, etc.) to ensure compliance.

On August 29, 2024, a landmark case validated this pathway’s business feasibility. Shenzhen Futian Investment Holding Co. (Fitch rating “A-”) successfully issued the world’s first RWA digital bonds listed on an exchange—“Fubì” (FTID TOKEN 001). The bond issuance totaled 500 million RMB, with a 2-year maturity, 2.62% coupon, issued as a digital token on the Ethereum blockchain, and dual-listed on Macau Financial Assets Exchange (MOX) and Shenzhen Stock Exchange.

“Fubì” is innovative because it is the first product globally to combine “public offering,” “listing,” and “RWA digital bonds.” The issuer has government credit backing, with underwriters including GF Securities (Hong Kong), CMB International, CICC, and Orient Securities, demonstrating that traditional financial institutions are becoming key drivers of RWA innovation.

Notably, the underlying assets of “Fubì” are the issuer’s own credit, not specific domestic asset pools, thus avoiding the “domestic asset outbound” issue highlighted in Document No. 42. It provides a complete compliance blueprint: how to issue on public blockchains, achieve dual listing, coordinate multi-jurisdictional regulation, and ensure smart contract security—laying the foundation for more RWA products in the future.

3. Who Is Acting, and What Are Their Intentions?

The opening of the policy window is always first sensed by market participants with keen awareness. Just after the release of Document No. 42, during that weekend, CICC Hong Kong team began engaging with major public chains and exchanges for cooperation. The timing is highly significant—it was not a follow-up after policy clarification but an urgent action during the same week of policy release.

Why is CICC Hong Kong so eager? As a leading Chinese securities firm, its client base includes many state-owned enterprises (SOEs) and central enterprises holding high-quality domestic assets. Against the backdrop of rising traditional financing costs and tight domestic liquidity, RWA offers a new financing channel: compliant tokenization of domestic assets to raise offshore funds from global investors. This serves both client financing needs and expands its investment banking业务线.

Simultaneously, tech giants like Ant Group and JD.com are also taking action. According to Caixin, both expressed high concern over policy changes, which quickly translated into substantive布局.

In August 2024, in cooperation with Longxin Group, a listed company on A-shares, they completed China’s first RWA project based on domestic new energy assets in Hong Kong. The project used Longxin’s charging stations as RWA collateral, issuing blockchain-based digital assets representing revenue rights of each station, raising about 100 million RMB. Wang Wei, CTO of AntChain, stated this is a new exploration in their overseas business, aiming to build a technological bridge for实体企业.

Ant’s布局 extends further. In May 2024, the Hong Kong Monetary Authority announced the architecture team for the wholesale CBDC project Ensemble, with AntChain’s ZAN (a Web3 brand) joining as a technology provider for tokenized deposit solutions. Previously, Ant Group had provided trusted modules and IoT tech for Shenzhen Dudu Battery Swap, enabling real-time tracking of battery health via blockchain.

JD.com has chosen a different track—stablecoins. In July 2024, the HKMA announced the participating firms in the stablecoin regulatory sandbox, with JD Chain Technology (Hong Kong) among the first. Later, Xiaomi and Shangcheng Group’s joint venture, Tianxing Bank, announced cooperation with JD Chain for stablecoin issuance. Industry analysts interpret JD’s move into stablecoins as a way to address cross-border payment bottlenecks—compared to traditional payments, stablecoins on blockchain can enable instant settlement, reducing time by over 100 times and costs by more than 10 times.

Earlier, Bank of China International also made moves—issuing a fully digital structured note worth 200 million RMB in Hong Kong via UBS in June 2023, becoming the first domestic financial institution to issue tokenized securities in Hong Kong.

From these actions, a common feature emerges: they are not “speculating on coins,” but using blockchain technology to transform the financing and circulation of实体资产. Ant targets new energy charging stations, JD focuses on cross-border payments, and CICC aims at investment banking—each seeking synergy with their core业务.

4. China’s Role in the RWA Wave

Expanding the view, China’s RWA布局 is not an isolated event but part of the global financial digitization wave.

BCG predicts that by 2030, the global tokenized asset market will reach $16 trillion, accounting for 10% of global GDP. Behind this forecast is the collective entry of top-tier financial institutions worldwide.

In March 2024, BlackRock launched its first tokenized fund on a public blockchain—the BlackRock USD Institutional Digital Liquidity Fund (BUIDL), surpassing $550 million by year-end. It mainly invests in cash, US Treasuries, and repos, offering qualified investors dollar yield opportunities. BlackRock’s exploration emphasizes compliance and security, collaborating with projects like Securitize and Maple Finance to ensure regulatory standards.

Goldman Sachs’ GS DAP platform helped European investment banks issue digital bonds as early as 2021. Giants like HSBC, JPMorgan, and Citi have also explored tokenized government bonds. In February 2023, HKMA issued HKD 800 million of tokenized green government bonds, a pioneering case of government-led RWA innovation.

Meanwhile, major economies accelerate virtual asset regulation legislation. The US House of Representatives passed the “Financial Innovation and Technology Act” (FIT 21) in May 2024, establishing clear legal frameworks for digital assets. The EU adopted the MiCA regulation in June 2023, the world’s first comprehensive crypto regulation, which will fully take effect by the end of 2024. The Monetary Authority of Singapore approved Paxos’ USDG stablecoin in July 2024, managed by DBS Bank. Japan proposed crypto income tax reforms in December 2024, aiming to lower the tax rate from 55% to 20% to attract international firms.

In this global wave, Hong Kong plays a unique “super connector” role. As Caixin noted, Hong Kong’s Web3 ecosystem needs to leverage the “one country, two systems” advantage to attract global capital, talent, and technology. Through offshore issuance and dual listings (“Fubì” on MOX and Shenzhen Stock Exchange), Hong Kong is opening channels between offshore and onshore markets, gaining recognition from mainstream capital markets.

5. Risks and Challenges: Finding Opportunities Amid Strict Regulation

Despite promising prospects, RWA development faces multiple challenges. Practitioners must stay alert.

Compliance risk is paramount. Yu Jianing (co-chair of the Blockchain Committee of China Communications Industry Association) pointed out that although Hong Kong has a solid financial infrastructure and favorable policies for RWA, the regulatory framework still needs further clarification and refinement. RWA involves complex issues like asset ownership, transaction security, and data privacy, and existing legal systems may not fully address these challenges.

Money laundering risk cannot be ignored. Recent interpretations by the Supreme People’s Court and Supreme People’s Procuratorate clarify that transferring or converting criminal proceeds via “virtual assets” can be recognized as money laundering. Since RWA transactions mainly occur on blockchain networks with strong anonymity, conventional risk control techniques may be insufficient. Industry insiders suggest enhancing on-chain monitoring, employing blockchain analysis tools to improve address analysis and risk tracking.

Technological risks also demand vigilance. Smart contract vulnerabilities, network outages, forks, and private key losses could cause investor losses. The “Fubì” issuance explicitly warns about smart contract risks and mitigates them through multiple audits and bug bounty programs. The stability and security of system architecture remain ongoing concerns.

Liquidity risk tests market depth. The secondary market for tokenized assets is still developing. Although “Fubì” achieved dual listing, on-chain market liquidity and traditional exchange liquidity may still be isolated, requiring intermediaries for asset conversion. Ensuring sufficient market depth and price stability is key to unlocking true liquidity for RWA.

Policy interpretation risks should not be underestimated. Regulators repeatedly emphasize that Document No. 42 “must not be interpreted as ‘encouraging’ or ‘rapidly expanding’.” Any misinterpretation of “strict regulation” as “promotion” could lead to regulatory risks. Practitioners must explore innovation within compliance boundaries, avoiding policy edge testing.

Conclusion: Finding Opportunities in Strict Regulation, Exploring Innovation within Compliance

Returning to the initial question: when CICC urgently meets with public chains over the weekend, when Ant and JD accelerate布局, and when “Fubì” is successfully issued and listed—these signals point to a conclusion: Document No. 42 is not a blanket ban on RWA but a detailed layered framework of “domestic ban, offshore strict regulation, Hong Kong exception.” Under the tone of “strict regulation,” the pathway of compliant “asset-backed securities tokens” is opening for the first time. This is the core reason leading institutions quietly布局.

The RWA Research Institute believes that this policy evolution’s significance lies in: it clearly defines the bottom line with “strict regulation” but also points the way with the specific tool of “asset-backed securities tokens.” When CICC begins discussions with public chains, it signals that the “institutional era” of Web3 is quietly beginning—finding opportunities amid strict regulation, exploring innovation within compliance.

The question for practitioners is no longer “whether to do,” but “how to do.” Does your asset fall under which “regulatory layer”? Do you have the capacity for transparent scrutiny? Are your partners licensed and compliant? Before answering these questions, any impulse to “rush to market” should be cautious.

The ultimate goal of RWA is not a contest between regulation and market but a compliant integration of finance and technology. The road will be bumpy, but the direction is already clear.

(This article is based on publicly available information and authoritative media reports and does not constitute investment advice. Markets carry risks; compliance is essential.)

References:

• “Risk Warning on Virtual Currency Trading and Speculation”

• “Deep Dive into Shenzhen Futian Investment’s ‘Fubì’ Issuance, the First Public RWA Digital Bond”

• “Big Tech Accelerates RWA布局, Web3 Re-emerges in China”

• “Hong Kong Web3 Ecosystem Needs to Fully Leverage ‘One Country, Two Systems’”

• “Notice on Further Preventing and Disposing of Virtual Currency Trading Risks”

• “Document No. 42 Emphasizes Strict Offshore RWA Regulation; CICC Hong Kong Has Engaged with Public Chains and Exchanges”

• “Major Firms Push Asset Tokenization Offshore; Safety and Compliance Remain Bottom Line”

• “Recent Regulatory Developments on Virtual Assets in Hong Kong”

• “2024 Public Chain RWA Annual Research Report”