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Original author: Lawyer Shao Jiadian
Introduction
Many RWA projects, when consulting a lawyer for the first time, almost always say the same thing:
“We are not securities, just a functional RWA token.”
“We simply put real assets on the chain, without financing attributes.”
“We are a utility token, not a security token.”
Honestly, I’ve become numb to these statements.
But the problem is—regulation is never determined by how you “call yourself,” but by “what you are actually doing.”
And an extremely important point is:
The gray buffer zone of “functional RWA tokens” has been gradually squeezed out by real case law in major regulatory jurisdictions worldwide.
Today, I will do only one thing in this article:
No abstract legal provisions, no vague theories, only real