What this is
Structuring an offering that gives investors exposure to UAE real estate through a token, in a way that works under the property regime and the virtual-asset regime at the same time.
The two-regime problem
The property side has to work: registration, escrow, and whatever the Land Department requires of the holding structure. The token side has to work: issuance rules, and the prior question of whether the instrument is a security rather than a virtual asset.
A structure that satisfies one and ignores the other is not a structure. Most of the work is in the join.
What the work involves
Choosing the holding vehicle. Obtaining the RERA and DLD approvals the structure needs. Drafting the issuance documentation. Building the AML programme, because real-estate brokers and developers are DNFBPs with their own reporting obligations. Documenting source of funds to a standard that survives the bank, the developer and the registry.
Paying for property in crypto
A separate and more common question. The practical answer is that value has to arrive in a form the escrow account can accept, which means conversion through a licensed provider with documented source of funds. It is a compliance exercise with a payment at the end.
Régulateurs
Questions fréquentes
Is tokenised property a security?
It can be. Fractional exposure to an income-producing asset managed by someone else has the shape of one. The analysis has to be done on the actual structure before anything is marketed.
Sources
- Scope of work described here reflects our practice, not a regulatory requirement — Regulatory statements on these pages carry the same review status as elsewhere on the site