The tokenized real-world asset market has climbed to about $38.86 billion, but Tiger Research argues that the harder question starts after launch: whether issuance, distribution, and repayment can actually function as a closed loop. In the structure outlined in its report, Korean underlying assets are packaged through an offshore special purpose vehicle, or SPV, and sold to overseas professional investors through licensed intermediaries in Hong Kong.
Using data from RWA.xyz, the report says the market for tokenized real-world assets expanded from about $1.5 billion in August 2023 to about $38.86 billion on Sept. 13, 2026, a roughly 26-fold increase. Growth, in other words, is already visible. The unresolved issue is how to turn an asset into a product that investors can buy and later be repaid on schedule.
The report says jurisdictions are writing tokenization rules at different speeds and with different requirements, making the place of issuance a direct factor in how quickly a product can reach market. Hong Kong is presented as one of the more workable venues because it has an established securities framework, channels to international investors, and prior experience with tokenized bond issuance, including government bonds.
A cross-border route from Korean assets to overseas investors
The structure in the report uses Korean assets as the base layer, while issuance and sales are handled through Hong Kong and the British Virgin Islands.
- A Korean securities company provides access to underlying assets such as listed shares, fund interests, and notes.
- A British Virgin Islands SPV buys and holds those assets through a brokerage account opened via the Hong Kong entity of the Korean securities company, then issues notes backed by the assets.
- A tokenization platform creates tokens representing the notes issued by the SPV and records issuance and allocation.
- A distributor sells the product to overseas professional investors through licensed intermediaries and compliant trading venues.
The subscription flow runs in parallel. Overseas professional investors subscribe using fiat currency or stablecoins, with funds moving through intermediaries to the SPV. If stablecoins are used, the SPV converts them into fiat through a centralized exchange. The money is then routed via the Hong Kong entity to the Korean securities company for the purchase of the underlying assets.
What matters here is not only the onchain record. The model depends on whether token issuance, the offshore issuing entity, traditional brokerage infrastructure, and final asset ownership can be linked in a way that holds up in practice.
The 26x market growth still runs into the repayment problem
Hong Kong fintech firm Finloop refers to this arrangement as a “dual-engine model.” One side is responsible for asset supply, and the other handles issuance and distribution. The report highlights three points.
First, the source of assets can be replaced. Securities companies in other countries, together with their Hong Kong entities, could take the place of the Korean institutions in the model. That would make Hong Kong a distribution channel for products backed by assets from multiple markets.
Second, the SPV sits at the center of the structure. It receives subscription funds, buys or holds the assets, and issues the notes. Investors assert their rights against the SPV under the product terms, not directly against the underlying assets. That makes the SPV’s legal claim over the assets, and its ability to pass through proceeds, central to the structure.
Third, the SPV links onchain payments to traditional finance. Investors can subscribe in stablecoins and hold tokenized notes, while the purchase and custody of the underlying assets are carried out through brokerage and custody arrangements.
The report says the setup works only if all of the necessary parts hold together at the same time: suitable underlying assets, a sound issuance structure, and a compliant route to investors. A product that sells is not automatically a product that can repay.
Cash flow rights and repayment coverage are the real test
Before a product is issued, the SPV must have clear legal rights to the cash generated by the underlying asset. The difficulty varies by asset type.
For government bonds or fund interests, the question may be whether the SPV can directly purchase and hold them. For export receivables or music royalties, the structure becomes more involved. The right to collect future payments may need to be assigned to the SPV, or the asset holder may need to take on a binding obligation to collect and remit those payments to the SPV.
In either case, the contracts must state who has the right to receive cash, who is responsible for collection, and how the funds reach the SPV. Without a clear repayment path, the asset cannot reliably support the issuer’s obligations to investors.
The report places the core of tokenization on the SPV itself. Even after the Korean asset is selected, a separate entity is still needed to issue the token and distribute proceeds to overseas investors. In Finloop’s version of the model, that role is assigned to a British Virgin Islands SPV, which becomes the connection point between Korean asset holders and overseas investors.
Investors buy an SPV-issued product, not the underlying asset
Under this structure, the SPV issues tokenized notes or securities backed by rights to proceeds from Korean assets. Overseas investors are therefore buying a financial product issued by the SPV, not the Korean government bond, export receivable, or other underlying asset itself. Under the product terms, the SPV pays investors the return and repays principal at maturity.
That shifts the focus to timing. For the structure to hold, the timing of cash inflows into the SPV must match its payment obligations to investors. Issuers need to confirm when each asset produces cash: coupon and principal payments on government bonds, fund distributions and redemption proceeds, or settlement flows from export receivables and royalties.
If investors must be paid before the SPV receives the money, the product may face a liquidity shortfall or delayed repayment.
The report also makes a separate point: establishing an offshore SPV does not by itself give that entity access to cash generated by Korean assets. Contracts still need to specify the SPV’s legal rights in the asset, who collects the money, and who remits it to the SPV. At the same time, the tokenization platform is expected to keep a transparent record of the issuance amount, token holdings, and token burns.
In that sense, the central task during the offshore issuance stage is practical rather than cosmetic: making sure the SPV can actually receive enough cash, and receive it in time to meet the payment terms promised to investors.
Hong Kong’s role is initial sale and investor qualification
After the product is set up through the offshore SPV, the issuer still needs a financial institution to distribute it. Finloop proposes the use of a licensed intermediary in Hong Kong that can review the product under Hong Kong securities rules, offer it to professional investors, and reach buyers outside Hong Kong.
The intermediary would review the SPV product terms and risks and confirm that each investor is eligible to buy. If the issuance is limited to professional investors, transfer of the token after issuance must remain restricted as well. The report says product terms would limit transfers to buyers whose eligibility has already been verified. It presents that as Finloop’s proposed structure for private placements, while also noting that the restriction does not apply to every tokenized security in Hong Kong.
Finloop also suggests that a product first sold in Hong Kong could later be offered through intermediaries and trading venues in other regions. Still, the report is clear that an initial sale in Hong Kong does not automatically authorize sales or trading elsewhere. Each market’s rules would have to be assessed separately.
For investors who want to sell before maturity, there must also be a willing buyer and a way to determine price. If the product is to be used as collateral, an institution still needs to agree to accept it.
So within this structure, Hong Kong provides the channel for the first sale and for investor eligibility checks. Sales and trading in other jurisdictions, and any collateral use, require separate arrangements.
Three risks can break the money flow
The report says a tokenized product may sell successfully in Hong Kong and still fail to make payments as promised. Cash generated by the underlying asset must pass through the offshore SPV and reach investors. It identifies three risks that can interrupt that process.
- Unclear rights and collection arrangements: for assets such as export receivables, contracts must specify where the buyer pays and who has the right to collect. Unless collection obligations and settlement steps are legally binding, the cash may never reach the SPV.
- A timing gap between cash recovery and investor repayment: if investors must be repaid before the underlying asset settles, the SPV may face a liquidity shortfall and delayed repayment. If won-denominated assets support a dollar-denominated product, exchange-rate moves and FX conversion costs may also reduce returns.
- Cross-border transfer and tax bottlenecks: approval for a Hong Kong intermediary to sell the product does not resolve how funds move from the Korean asset holder to the offshore SPV, or how investors overseas get paid. Those transfer and tax processes must work in practice.
In the end, the model stands or falls on a narrow question: whether cash generated by Korean assets can move through the SPV to overseas investors in full and on time, exactly as the contracts require.
What decides the market’s future is repeatability after the first deal
The report says selling one product in Hong Kong that is backed by Korean assets is only a starting point. The first issuance usually takes longer because the parties need to review the assets, finalize the contracts, and decide how the product will be sold.
If every new product requires the whole process to start again from zero, the business will be difficult to scale. The real pressure test comes after the first deal, when the market tries to issue a second one using the same framework.
The report points to dollar-settled export receivables as one way to test whether the model works. Issuers and intermediaries could reuse debtor assessment standards and disclosure methods developed for the first deal in later receivables products, reducing the amount of work needed to design each new product. But using the same standards does not mean each receivable carries the same risk.
To judge whether the model can support a continuing market, the report says three points need to be tracked:
- whether the time required for asset review falls with each issuance;
- whether existing investors come back for new products; and
- whether asset holders have reason to keep supplying assets.
As experience builds with export receivables, the structure could be extended to other Korean assets. The report ends on a practical note. Success is not defined by a single completed issuance. It depends on whether asset holders continue to supply suitable assets, investors are willing to reinvest, and intermediaries still see value in bringing new products to market.