If the "Asset Side" of RWA defines what constitutes a compliant financial token, then the "Infrastructure Side" determines whether these tokens can circulate safely and smoothly in the market. In the latest guide released by the Monetary Authority of Singapore (MAS), the regulatory reach has extended from solely the issuer to the entire value chain—including trading platforms, custodians, advisors, and technology service providers.

As the second report in this series, this article interprets MAS's new requirements for Asset Custody, Technical Disclosure, Anti-Money Laundering (AML/CFT), and Cross-border Compliance from the perspective of Infrastructure. For RWA projects, choosing a trading ecosystem capable of integrating compliance resources and providing full-chain support is key to achieving scalable asset circulation.

I. Redefining "Custody": Private Key is Control, Control is Responsibility

In the traditional Web3 narrative, many platforms claim to be "Non-custodial" to avoid regulatory responsibility. However, MAS has closed this regulatory arbitrage gap through extremely granular technical definitions in the new regulations.

The New Regulatory Yardstick: Shards Are Also Custody

MAS explicitly states in Guide Section 4.6 that if an entity has "Control" over a token, it is considered to be providing custodial services.

The definition of "Control" here is far broader than industry perception:

• Not Just Full Private Keys: Even if an entity holds only Key Shards, or acts as a party in a Multisig arrangement, as long as the portion held can jointly authorize the execution of a transaction, that entity is deemed to possess control.
• Compliance Warning for MPC: This means that many service providers offering MPC (Multi-Party Computation) wallet technology must hold a custodial license under the Capital Markets Services (CMS) license if the shards they safeguard can substantively affect asset transfer.

Building a Layered Custody Matrix

Facing MAS's high standards, Bifu is committed to building an open, compliant custody ecosystem.

• Institutional-Grade Assets: Collaborative Licensed Custody For high-net-worth and institutional-grade RWA assets (e.g., tokenized treasuries, real estate funds), Bifu requires and assists project owners in connecting with Third-party Licensed Custodians (Qualified Custodians) that meet MAS standards.

Bifu Advantage: We have established strategic partnerships with top tier custodians to achieve legal isolation between asset ownership and the trading platform. Even in the event of extreme risk at the exchange, users' underlying assets remain safely kept in trust accounts.

• Innovative Assets: Technical Compliance Verification For small and medium-cap projects using self-custody or decentralized technology, Bifu requires project owners to engage independent third-party security agencies for code audits, and the Bifu Security Team reviews their audit reports and disaster recovery drill results.

II. New Paradigm for Prospectus: Code Risks Must Be "Translated" into Legal Language

MAS is the first regulator globally to explicitly require the disclosure of underlying technical risks in a Prospectus (Section 3). This marks the transition of RWA issuance from "Financial Compliance" to an era of "Financial + Technical Dual Compliance."

The "Black Box" of Technology Must Be Opened

According to the Guide, issuers cannot only discuss asset returns; they must disclose the following "hardcore" details to investors:

• Network Robustness: Is a Public Chain or Permissioned Chain used? If a 51% attack or on-chain congestion occurs, is there a contingency plan?
• Smart Contract Audit: Who audited the code? Are there any unpatched vulnerabilities?
• Finality: When is an on-chain transfer legally considered "irrevocable"? If on-chain records conflict with the Off-chain Register, which prevails?

Bifu's Service: Listing Guidance and Standardized Disclosure

We understand that it is difficult for many traditional asset owners to describe blockchain technical risks in precise language. Bifu provides "Translation" services in this segment:

• Bifu Technical Disclosure Checklist (Example): During the listing review, we assist project owners in refining the following disclosure points:
  • Private Key Management: Clarify whether assets are automatically controlled by smart contracts or by administrator multisig.
  • Blacklist Mechanism: Does the issuer have the power to freeze tokens at specific addresses? (This is crucial for compliance).
  • Fork Contingency: In the event of a blockchain hard fork, on which chain is the RWA asset mapped?

III. Invisible Red Lines: Anti-Money Laundering (AML) and the Travel Rule

In MAS Guide Section 4.8, Anti-Money Laundering (AML) and Countering the Financing of Terrorism (CFT) have been elevated to unprecedented importance. This is not only the responsibility of the exchange but also an obligation that all RWA issuers must fulfill.

On-Chain Value Transfer Rules

MAS requires that the "Travel Rule" must be observed when transferring tokens. This means:

• When RWA tokens are transferred from one wallet to another (especially involving exchanges or custodians), the identity information of the Originator and Beneficiary must be attached.
• Traditional "anonymous transfer" modes will face strict restrictions under the compliant RWA system.

Compliance Escort

Bifu integrates industry-leading on-chain analysis and compliance tools to provide RWA projects with:

• Real-time Transaction Screening: Automatically intercept funds from sanctioned addresses (e.g., Tornado Cash).
• Identity Anchoring: Ensuring that every RWA transaction can be traced when required by regulations, satisfying international FATF standards, while protecting user privacy.

IV. Cross-Border Operations: The Applicable Boundaries of Extra-territoriality

MAS cites Section 339 of the Securities and Futures Act (SFA), emphasizing its powerful Extra-territoriality.

The Failure of Offshore Structures

Many project owners mistakenly believe that registering entities in the Cayman Islands or BVI can circumvent Singaporean regulation. MAS explicitly states:

• As long as the issuance activity is carried out Partly in Singapore;
• Or even if carried out overseas, it has a Substantial and Reasonably Foreseeable Effect on the Singapore market;
• Result: The project must comply with Singapore's securities laws.

Solution: Technical Segmentation and Compliance Routing

For projects at different compliance stages, Bifu provides flexible and rigorous market access solutions:

• Geo-fencing: For projects that have not yet obtained a public offering license in Singapore, Bifu uses mature geolocation and KYC technologies to strictly restrict access by Singapore retail users at the frontend. This protects project owners from allegations of non-compliance and ensures the compliance of platform operations.
• Regulatory Sandbox Channel: For innovative projects intending to operate long-term in Singapore, Bifu can introduce them to apply for the MAS Regulatory Sandbox through our ecosystem partner network, helping them achieve compliant landing in a controlled environment.

V. Conclusion: Building a Sustainable Compliance Infrastructure Ecosystem

The new MAS regulations clearly indicate that RWA is no longer simply "issuing tokens," but a complex systems engineering project involving legal confirmation, technical auditing, asset custody, and AML risk control.

In this ecosystem, Bifu Exchange acts not only as a provider of liquidity but as a "Super Connector" of compliance resources.

We do not produce assets, but we collaborate with top global law firms, auditors, and custodians to set access standards for assets; we do not directly hold all assets, but we ensure that every asset operates under a compliant framework. Bifu is committed to presenting users with RWA assets that can truly withstand regulatory scrutiny through a rigorous screening system and a powerful partner ecosystem.

(Figure Note: Bifu RWA Compliance Ecosystem Architecture. Bifu sits at the core, connecting issuers, third-party custodians, compliant law firms, technical auditors, and AML service providers to jointly build an asset issuance environment that meets MAS standards.)

Disclaimer

This report is prepared by the Bifu Research Institute for informational purposes only and does not constitute investment advice, legal opinion, or endorsement of any specific asset. The digital asset market is highly volatile and risky; past performance is not indicative of future returns. Users should fully assess risks and consult professional advisors before investing.

Policy interpretations in this report are based on the regulatory environment at the time of publication. As local laws and regulations may update and adjust over time, please always refer to the latest documents published by official regulatory bodies for specific compliance requirements. Bifu assumes no legal liability for any decisions made based on this report.

Reference: https://www.mas.gov.sg/regulation/guidelines/guide-on-tokenisation-of-cmps