Together with
Hello readers. The liquidity question that follows every tokenized real estate conversation just got its first regulated, operational answer.
Dubai proved a compliance-first secondary market can work, a $125B US operator confirmed demand publicly, and US settlement infrastructure cleared its first live trades through a regulated ATS.
The question now shifts from "is this real?" to "which jurisdictions and asset classes move next?"
In this weeks ReFi Brief:
The Big Read: What Dubai's Registry-Synchronized Secondary Market Means for Your Liquidity Promise
[NEW] Brief Deal Breakdown: How A Luxembourg Operator Raised €1.7M from 250 Investors at €50/Month
DarGlobal, Securitize to tokenize Trump International Hotel & Resort Maldives
Starwood's $125B firm confirms tokenization readiness
BitGo & Figure complete first blockchain-native equity trades through regulated ATS
THE BIG READ
Dubai Activates Regulated Secondary Market for Tokenized Property
Dubai's Land Department activated the secondary market for tokenized property interests on February 20, making it possible for investors holding fractional stakes in real estate to buy, sell, and transfer them through a live, regulated marketplace.
This is not a sandbox or a pilot extension. It is an operational secondary market backed by three regulators: the Dubai Land Department, VARA, and the Central Bank of the UAE.
For developers and operators who have heard "but where's the liquidity?" from every investor conversation about tokenization, Dubai just provided a referenceable answer.
The system went live after a nine-month pilot that processed AED 18.5 million across ten properties, with participants from over 50 nationalities. Modest by institutional standards, but real transactions through a compliance framework that now supports ongoing secondary trading.
Let’s explore.
What Does "Registry-Synchronized" Actually Mean for Your Cap Table?
The technical detail that matters most is not the blockchain or the trading app. It is the synchronization between the on-chain record and the DLD's official title deed registry. When a token changes hands on the PRYPCO Mint marketplace, the DLD's ownership records update in real time.
The tokenization infrastructure here is provided by Ctrl Alt, which holds VARA Issuer and Broker-Dealer licenses, with transactions settling on the XRP Ledger and assets secured through Ripple Custody.
This solves the "source of truth" problem that has stalled institutional tokenization elsewhere. In most models, the token ledger and the official property registry are separate systems requiring manual reconciliation. Dubai eliminated that gap.
For operators managing fractional interests across dozens or hundreds of investors, the cap table is always current, always auditable, and always aligned with the sovereign registry. That is an operational efficiency change, not just a capital markets innovation.
Why You Cannot Replicate This Tomorrow
The compliance architecture includes specific constraints designed to prevent speculative volatility. Sellers can only list tokens within 15% of the current DLD valuation, preventing price decoupling from fundamental property value.
A 20% ownership cap per investor is enforced programmatically to maintain distributed ownership. And a three-month lock-in period applies before any secondary resale.
These are features, not bugs. They are the mechanisms a professional secondary market needs to maintain credibility with institutional capital. But the ARVA classification that makes this legal is unique to Dubai's regulatory framework.
Participation is currently restricted to UAE residents with valid Emirates IDs. International access has been flagged for future phases, but I couldn't find public documentation confirming a timeline.
What Transfers and What Does Not
The compliance mechanisms are the globally transferable element. Valuation-pegged trading bands, ownership concentration limits, mandatory lock-ins, and registry synchronization are design principles applicable to secondary market frameworks in any jurisdiction.
The specific regulatory wrapper is Dubai's. The design logic is not.
If you manage a portfolio with fractional investors and have been telling them liquidity is "coming," Dubai just defined what a compliant version looks like. The question for operators elsewhere is whether their regulators will adopt similar frameworks.
For those in the GCC, the DLD's Phase 2 announcement is the benchmark neighboring regulators are now evaluating.
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TOGETHER WITH ONCHAIN REAL ESTATE
The Brief: Onchain Real Estate brings together the world’s leading real estate players and top blockchain companies to accelerate the adoption of onchain capital assets.
As the flagship global gathering for tokenized real estate, it’s built for decision-makers driving innovation, forging partnerships, and executing real-world strategies that connect the built environment with the blockchain economy.
Let’s meet on 28 April 2026 in Dubai
Who is attending?
Real Estate Developers & Institutional Owners
Asset Managers, Funds & Institutional Investors
Tokenization Platforms & Infrastructure Providers
Blockchain, RWA & DeFi Ecosystem Leaders
The Onchain Real Estate Summit is designed to spark meaningful connections and drive forward-looking partnerships whether you're exploring tokenization, bridging traditional and digital markets, or expanding your global footprint.
Brief Deal Breakdown
BLOCHOME / CLAPTON RESIDENCE, LUXEMBOURG
Image Source: BlocHome, Clapton Residence
The Brief: A team of Luxembourg real estate operators, led by the President of the country’s Real Estate Board, tokenized a fully occupied nine-unit residential building and raised €1.7M from 250 investors through monthly subscription plans starting at €50. The structure runs under CSSF oversight with a regulator-accepted P2P secondary market for exits.
The Details:
Structure: Investors hold Class B digital shares in a Luxembourg Securitization Vehicle via ERC-3643 permissioned tokens on Polygon, with Euro-only bank transfer payments and automated KYC/AML through Tokeny’s T-REX platform.
Numbers: €8M building valuation; €1.7M raised from initial cohort; weekly capital inflows of €25K-€100K during growth phase; 100% occupancy at acquisition.
Distinctive feature: The CSSF accepted BlocHome’s “Billboard” P2P matching engine as a secondary market for a non-regulated public offering, providing regulator-backed exit flexibility without requiring exchange-level infrastructure.
Replication: The community voted to acquire a second building (Flora Residence, Howald) with 350+ active investors, demonstrating that the capital-pooling and governance mechanisms function beyond a single asset.
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THE WEEK IN BRIEF
Image Source: DarGlobal
The Brief: DarGlobal PLC, an LSE-listed international developer, is tokenizing loan revenue interests in a $300 million luxury resort in the Maldives through Securitize, with World Liberty Financial as the financial structuring partner. DarGlobal is retaining a minimum 30% equity stake in the project.
The Details:
The offering is structured under Reg D 506(c) for US accredited investors and Reg S for offshore participants, with Securitize handling KYC/AML and investor verification at the platform level.
The instrument is a loan revenue interest rather than direct equity or fractional ownership, giving investors fixed yield plus a share of loan revenue streams during construction and an exit mechanism for liquidity before the 2030 completion date.
The prospectus has not been filed; the waitlist is operational at securitize.io/wlfi, but the specific mechanics of the exit mechanism remain undisclosed pending that document.
What This Means: Developers seeking construction-phase capital should pay attention to the loan revenue interest model, which converts what would traditionally be a single-source institutional loan into a distributed, tokenized obligation under a well-established US exemption pathway.
The 30% retained equity is notable; it is three times the typical 10% industry standard and signals that developer alignment is becoming a competitive requirement for tokenized capital raises.
GO ONCHAIN WITH EVERGON
The Brief: The path from evaluating tokenization to launching a compliant offering is fragmented, expensive, and jurisdiction-dependent. Developers face a maze of legal structuring, compliance infrastructure, and platform selection decisions before a single token is issued.
Evergon’s newly published Tokenization Handbook 2026, co-authored by 13 industry experts, provides developers with cost benchmarks, failure pattern analysis, and jurisdiction-specific guidance for evaluating whether tokenization fits their deal size and market.
The Details:
The handbook publishes specific cost benchmarks rarely available in one place. From structuring and pre-issuance, to technology infrastructure depending on your build path.
It identifies three failure patterns that cause tokenization projects to stall, none of them technical: error in scope (building everything at once), error in structuring (launching with unnecessary complexity), and error in technology choice (locking into rigid infrastructure that cannot adapt when regulations change).
It includes jurisdiction-specific guidance comparing how Dubai and Saudi Arabia are integrating tokenization into official land registries, with practical distinctions for developers evaluating each market.
Starwood Capital's Sternlicht Confirms $125B Firm Is Ready to Tokenize, Names US Regulation as Sole Barrier
Image Source: CoinDesk
The Brief: Barry Sternlicht, chairman of Starwood Capital Group, said publicly that his firm, which manages over $125 billion in real estate assets, is operationally ready to tokenize but cannot proceed due to US regulatory barriers. He made the statement at the World Liberty Forum in Palm Beach on February 18.
The Details:
Starwood's portfolio includes approximately 250,000 residential units and significant commercial holdings across multiple continents, making this the largest operator to publicly confirm tokenization readiness.
Sternlicht stated the firm wants to offer blockchain-based tokens to clients immediately but did not detail which specific regulatory provisions are blocking plans; the barriers likely involve securities law, broker-dealer registration, custody requirements, and investor eligibility standards.
No tokenized Starwood offering exists or has been filed; this is a statement of operational readiness and institutional demand, not a deal announcement, and no timeline for a US regulatory resolution was identified.
What This Means: US operators weighing whether institutional capital takes tokenization seriously now have a direct answer from one of the largest private real estate firms in the world.
When a $125B manager says publicly that the technology works and regulation is the only barrier, that is a demand-side validation receipt for the sector.
I'd add that Sternlicht's frustration highlights the gap: the US still lacks a clear pathway for tokenized fund shares to retail investors, and until that changes, even ready firms stay on the sideline.
Image Source: BingX
The Brief: BitGo and Figure completed the first equity trades executed entirely within a blockchain-native environment, through Figure's regulated Alternative Trading System on the Provenance Blockchain. BitGo Bank & Trust, a federally chartered institution, provided custody.
The Details:
Figure's OPEN network operates as an SEC-registered, FINRA-member broker-dealer ATS, meaning all trades meet standard market oversight requirements while using blockchain for settlement.
The equities are registered natively on the blockchain rather than tokenized versions of existing DTCC-registered securities, enabling atomic settlement where ownership transfer and payment occur simultaneously and eliminating multi-day reconciliation.
No real estate fund is currently using this infrastructure; the completed trades involved corporate equities, and the gap between equity trading and real estate fund interest trading involves asset-specific regulatory and structural work.
What This Means: Real estate fund managers tracking when on-chain settlement reaches their asset class should note that the infrastructure pattern (unified on-chain environment, regulated ATS, federally chartered custodian) is now proven in production for equities.
This removes the "technical feasibility" concern from institutional evaluation. The remaining question is asset-specific: transfer restrictions, accredited investor verification, and Reg D compliance for real estate funds.
EXPERT TAKEAWAY
“Saudi Arabia is running a live policy laboratory for tokenized real estate.”
Jeanina Awni, Director of Tech Law & Innovation at AlMikial Law Firm, analyzes REGA’s nine authorized tokenization platforms and how they define ownership models, licensing pathways, and infrastructure layers in Saudi Arabia’s pre-law phase.
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See you in the next brief,
Tatenda