Jersey tokenisation of real-world assets (RWAs), the regulatory framework as of September 2025

The tokenisation of real-world assets cannot be ignored. The AUM of tokenised assets globally, for instance, stood at US$5.2 billion in 2022, rising to US$8.5 billion in 2023.  In 2024, the figure almost doubled to US$15.7 billion, and in 2025, it increased further to US$25.3 billion (as of August 2025, RWA.XYZ).

In Jersey, just over a year ago—on 28 August 2024—the Jersey Financial Services Commission (JFSC) issued updated guidance on the tokenisation of real-world assets (RWAs).

This move was indeed warmly welcomed by Jersey’s funds and digital assets industry, as it provided much-needed clarity and regulatory certainty for both issuers and investors.

Key Highlights of the JFSC Guidance:

1. Purpose of the Guidance:
• To support the tokenisation of physical and traditional financial assets (like real estate, art, bonds, fund interests) into digital tokens on a blockchain.
• To ensure a proportionate regulatory framework that balances innovation with investor protection and market integrity.
2. Issuer Requirements:
• Must be a Jersey-incorporated company or LLC.
• Must be administered by a regulated Jersey corporate services provider (CSP).
• Must obtain regulatory consent from the JFSC before issuing tokens.
• Must comply with AML/CFT/CPF standards, including KYC/CDD checks on token purchasers and redeemers.
• Must submit a whitepaper or offer document meeting specific content requirements
3. Stablecoins:
• Now treated as tokenised fiat currencies, not cryptocurrencies.
• Must be fully asset-backed by low-risk assets (e.g., cash, money market funds).
• Applications must include detailed information on collateral, liquidity, custody, and redemption mechanisms
4. Principles-Based Approach:
• The JFSC has adopted a substance-over-form regulatory philosophy.
• This allows flexibility in how tokenised products are structured, while ensuring the underlying economic reality is adequately understood and regulated.
5. Industry Reception:
• The guidance has been praised for enhancing Jersey’s competitiveness in the digital asset space.
• It provides execution certainty and aligns tokenisation with existing securitisation frameworks, offering a more robust alternative to jurisdictions relying solely on legal opinions

Here is a summary of how the JFSC’s tokenisation guidance can be integrated into a compliance framework, particularly for firms operating in Jersey’s financial services or funds sector:

1. Governance & Oversight

• Board-level awareness: Ensure the board understands the implications of tokenisation and the JFSC’s expectations.
• Policies & procedures: Update internal governance documents to reflect tokenised asset issuance, custody, and redemption processes.

2. Regulatory Classification & Licensing

• Determine regulatory status: Assess whether the tokenised product qualifies as a security, fund interest, or other regulated instrument.
• Consent & registration: Obtain JFSC consent under the Control of Borrowing (Jersey) Order (COBO) or other applicable regimes.

3. Whitepaper / Offer Document Compliance

• Include:
• Description of the token and underlying asset.
• Rights attached to the token.
• Redemption mechanisms.
• Risk disclosures.
• AML/CFT compliance measures.

4. AML/CFT/CPF Controls

• KYC/CDD: Apply full due diligence to token purchasers and redeemers.
• Ongoing monitoring: Implement transaction monitoring tools for blockchain-based activity.
• Sanctions screening: Ensure wallet addresses and counterparties are screened.

5. Custody & Asset Backing

• For stablecoins or tokenised assets, ensure:
• Custody arrangements are robust and transparent.
• Assets are held with regulated custodians.
• Backing assets are low-risk and liquid (e.g., cash, MMFs).

6. Cybersecurity & Technology Risk

• Conduct IT risk assessments on smart contracts, wallets, and blockchain infrastructure.
• Ensure incident response plans cover token-related breaches or fraud.

7. Reporting & Record-Keeping

• Maintain detailed records of:
• Token issuance and redemption.
• Investor onboarding and KYC.
• Smart contract audits and changes.
• Prepare for regulatory reporting obligations.

8. Service Provider Due Diligence

• Vet and monitor:
• Blockchain developers.
• Custodians.
• Tokenisation platforms.
• Legal and compliance advisors.

Tokenised Asset Risk Matrix (JFSC Framework)

This risk matrix is tailored to tokenised assets under the Jersey Financial Services Commission (JFSC) 2024 guidance. It helps compliance teams identify, assess, and mitigate key risks across the lifecycle of tokenised products.

References

[1] Tokenisation of real-world assets (RWAs) - Jersey Financial Services ... https://www.jerseyfsc.org/industry/guidance-and-policy/tokenisation-of-real-world-assets-rwas/

[2] Jersey publishes new guidance on the tokenisation of RWAs https://www.careyolsen.com/insights/briefings/jersey-publishes-new-guidance-tokenisation-rwas

[3] Navigating Jersey’s new guidance on real-world assets - IQ-EQ https://iqeq.com/insights/navigating-jerseys-new-guidance-on-real-world-assets/

[4] JTC Welcomes Updated Jersey Guidance On Real-World Asset Tokenisation - JTC https://www.jtcgroup.com/news/jtc-welcomes-updated-jersey-guidance-on-real-world-asset-tokenisation/