When gold and real estate are 'on the chain': is it a financial revolution, or is the 'scamcoin' dressed in a suit?

Reprint: Daisy, Mars Finance

Industry observers often assert online that "RWA will reshape the new financial ecosystem in Hong Kong," believing that relying on the existing regulatory framework of the Hong Kong SAR, this sector will experience breakthrough development.

Recently, discussions about RWA projects have been fervent in various Web3 communities. Industry observers often assert online that "RWA will reconstruct the new financial ecosystem of Hong Kong," believing that leveraging the existing regulatory framework of the Hong Kong Special Administrative Region, this sector will experience breakthrough development. During discussions with colleagues, Crypto Salad discovered that everyone has been debating the so-called "compliance" issue, and their understanding of "what is compliance" varies, leading to a situation where both sides have their own valid points. This phenomenon actually stems from differing understandings of the RWA concept.

Therefore, it is necessary for the crypto salad to discuss from the perspective of a professional lawyer team how the concept of RWA should be defined and to clarify the compliance red lines of RWA.

How should the concept of RWA be defined?

(1) Background and Advantages of RWA Projects

Currently, RWA is becoming the focus of market discussions and is gradually forming a new wave of development. This phenomenon is mainly based on the following two major backgrounds:

First, it is because the advantages of the tokens themselves can compensate for the shortcomings of traditional financing.

Traditional financial market projects have long faced inherent shortcomings such as high entry barriers, long financing cycles, slow financing speeds, and complex exit mechanisms. However, token financing can effectively bypass these defects. Compared to traditional IPOs, RWA has the following significant advantages:

1. Fast financing speed: Due to the circulation of tokens based on blockchain technology, which usually circulates in decentralized intermediary trading institutions, it avoids obstacles such as foreign investment access restrictions, industry policy constraints, and lock-up period requirements that traditional financial projects may encounter. At the same time, it can also compress the review process that originally takes months or even years, greatly improving the financing rate.

2. Asset Diversification: Traditional IPOs have a single type of asset, only supporting equity issuance, thus imposing strict requirements on the revenue stability, profitability, and asset-liability structure of the issuing entity. However, for RWA, the suitable types of assets are more diverse, encompassing various types of non-standard assets, which not only expands the range of assets that can be financed but also shifts the focus of credit assessment to the quality of underlying assets, significantly lowering the qualification threshold for the issuing entity.

3. Relatively low financing costs: Traditional IPOs require long-term collaboration among various intermediaries such as investment banks, auditors, and law firms, with the total listing process costs reaching millions or even tens of millions, which is a huge expense. However, RWA issues tokens through decentralized exchanges, eliminating a significant amount of intermediary fees, while also reducing another large portion of labor costs through the operation of smart contracts.

In summary, RWA has taken the spotlight in financing projects with its unique advantages, while the Web3 world and the cryptocurrency space particularly need funds and projects from the traditional real world. This has led to a situation where, whether aiming for substantial business transformation or simply wanting to "ride the wave" and gain attention, both leading projects in niche sectors of public companies and a wide variety of bottom-tier startup projects are actively exploring the potential applications of RWA.

Secondly, Hong Kong's "compliance" has added fuel to the enthusiasm.

Actually, the development of RWA overseas has been going on for a while. This surge in popularity is due to a series of regulatory innovations passed in Hong Kong, which implemented several benchmark projects, providing domestic investors with a compliant channel to participate in "RWA" for the first time. The "compliant" RWA that can be accessed by the Chinese people has been realized. This groundbreaking progress has not only attracted native crypto assets but has also prompted traditional projects and funds to start paying attention to the investment value of RWA, ultimately driving market enthusiasm to new heights.

However, do users who want to experience RWA really understand what RWA is? There are various RWA projects, with underlying assets and operational structures all over the place. Can everyone distinguish their differences? Therefore, we believe it is necessary to clearly define what compliant RWA is through this article.

People generally believe that RWA is a financing project that tokenizes underlying real-world assets through blockchain technology. However, when we delve into the underlying assets of each project and trace back the operational process of the projects, we find that the underlying logic of these projects is actually different. We conducted a systematic study on this issue and summarized our understanding of the concept of RWA as follows:

We believe that RWA is actually a broad concept and does not have a so-called "standard answer." The process of asset tokenization achieved through blockchain technology can all be referred to as RWA.

(2) Elements and Characteristics of RWA Projects

Real RWA projects need to have the following characteristics:

1. Based on real assets

The authenticity of the underlying assets and whether the project team can establish a transparent and acceptable off-chain asset verification mechanism through third-party audits are key criteria for determining whether the project token will realize effective value recognition in reality. For example, PAXG issues tokens that are pegged to gold in real-time, with each token backed by 1 ounce of physical gold. The gold reserves are managed by a third-party platform and audited quarterly by a third-party auditing company, and it even supports redeeming a corresponding amount of physical gold with the tokens. This high level of transparency and regulated asset verification mechanism enables the project to gain investor trust and provides a basis for effective valuation within the real financial system.

2. Asset Tokenization on Chain

Asset tokenization refers to the process of converting real-world assets into digital tokens that can be issued, traded, and managed on-chain through smart contracts and blockchain technology. The value circulation and asset management processes of RWA are executed automatically through smart contracts. Unlike traditional financial systems that rely on intermediary institutions for transactions and settlement, RWA projects can leverage smart contracts to achieve transparent, efficient, and programmable business logic execution on the blockchain, significantly enhancing asset management efficiency and reducing operational risks.

Asset tokenization endows RWA with key characteristics of being divisible, tradable, and highly liquid. After asset tokenization, assets can be split into smaller tokens, lowering the investment threshold and changing the way assets are held and circulated, allowing retail investors to participate in investment markets that were originally high-threshold.

3. Digital assets have ownership value

The tokens issued by RWA projects should belong to digital assets with property attributes. The project team should clearly distinguish between data assets and digital assets: data assets are the collection of data owned by an enterprise that can create value. In contrast, digital assets are the value itself and do not require repricing through data. For example, when you design a painting, upload it to the blockchain, and generate an NFT, this NFT is a digital asset because it can be certified and traded. However, the large amount of feedback from users regarding this painting, browsing data, click rates, and other data belong to data assets. You can analyze data assets to determine user preferences, improve your work, and adjust its price.

4. The issuance and circulation of RWA tokens comply with legal regulations and are subject to administrative supervision.

The issuance and circulation of RWA tokens must be carried out within the existing legal framework, otherwise it may not only lead to the failure of the project, but also may lead to legal risks. First of all, real-world assets must be real, legitimate, and have clear ownership without disputes, so that they can serve as the basis for token issuance. Second, RWA tokens usually have income rights or equity in assets, which can easily be recognized as securities by regulators in various countries, so they must be handled in compliance with local securities regulations before issuance. The issuer must also be a qualified institution, such as holding an asset management or trust license, and complete KYC and anti-money laundering procedures. After entering circulation, the trading platform of RWA tokens also needs to be regulated, usually requiring a compliant exchange or a secondary market with a financial license, and no random trading on a decentralized platform is allowed. In addition, information disclosure is required on an ongoing basis to ensure that investors have access to the true picture of the assets linked to the token. Only under such a regulatory framework can RWA tokens be legally and safely issued and circulated.

In addition, RWA's compliance management has typical cross-jurisdictional characteristics, so it is necessary to establish a systematic compliance framework covering the legal norms, capital flow routes, and various regulatory authorities where the assets are located. In the whole life cycle of asset on-chain, cross-chain, and cross-border and cross-platform circulation of tokens, RWA must establish a compliance mechanism covering multiple links such as asset confirmation, token issuance, capital flow, revenue distribution, user identification, and compliance audit. This involves not only legal advice and compliance design, but may also require the introduction of third-party trust, custody, auditing, and regulatory technology solutions.

(3) Types and Regulation of RWA Projects

We found that there are two parallel types in the eligible RWA projects:

1. Narrow definition of RWA: Tokenization of physical assets

We believe that the narrow definition of RWA specifically refers to projects that tokenize real assets with authenticity and verifiability on the blockchain, which is also the widely understood concept of RWA. Its application market is the most extensive, such as projects that anchor tokens to real assets like real estate and gold.

2. STO (Security Token Offering): Financial assets on the blockchain

Apart from the narrow definition of RWA projects, we have found that there are currently a large number of RWA projects in the market that are STOs.

(1) Definition of STO

Based on the differences in underlying assets, operational logic, and token functions, existing tokens in the market can be roughly divided into two main categories: Utility Tokens and Security Tokens. STO refers to the process of financializing real assets and issuing tokenized shares or certificates in the form of Security Tokens on the blockchain.

(2) Definition of Security Tokens

Compared to functional tokens, security tokens are, simply put, on-chain financial products driven by blockchain technology that are subject to securities regulations, similar to electronic stocks.

(3) Regulation of Security Tokens

Under the regulatory framework of mainstream crypto-friendly countries such as the United States and Singapore, once a token is identified as a security token, it will be subject to the constraints of traditional financial regulatory agencies (such as the SEC), and the token's design, trading models, etc., must comply with local securities regulations.

From the perspective of economics, the core goal of financial products is to coordinate the supply and demand relationship between financiers and investors. From the perspective of legal regulation, some countries are more focused on protecting the interests of investors, while others are more inclined to encourage smooth and innovative financing behavior. This difference in regulatory stance is reflected in the specific rules, compliance requirements and enforcement levels of each country's legal system. Therefore, when designing and issuing RWA products, it is necessary not only to consider the authenticity and legitimacy of the underlying assets, but also to conduct a comprehensive review and compliance design of key links such as product structure, issuance method, circulation path, trading platform, investor access threshold and capital cost.

It is particularly noteworthy that once the core appeal of a certain RWA project comes from its high leverage and high return expectations, and positions "hundredfold, thousandfold returns" as its main selling point, then regardless of how it is superficially packaged, its essence is highly likely to be classified as a securities product by regulatory authorities. Once identified as a security, the project will face a more stringent and complex regulatory system, and its subsequent development path, operating costs, and even legal risks will also be significantly heightened.

Therefore, when exploring the legal compliance of RWA, we need to deeply understand the connotation of "securities regulations" and the regulatory logic behind it. Different countries and regions have varying definitions and regulatory focuses on securities. The United States, Singapore, and Hong Kong have all defined criteria for identifying security tokens. It is not difficult to see that the defining method is essentially to determine whether the tokens meet the local securities regulations' identification standards for "securities"; once they satisfy the criteria for securities, they are classified as security tokens. Therefore, we have compiled the relevant provisions from key countries (regions) as follows:

A. Mainland China

In Chinese mainland's regulatory framework, the Securities Law of the People's Republic of China defines securities as stocks, corporate bonds, depositary receipts and other negotiable certificates recognized by the State Council as being issued and traded, and the listing and trading of government bonds and securities investment fund shares are also included in the regulation of the Securities Law.

(The above image is taken from the Securities Law of the People's Republic of China)

B. Singapore

Although the concept of "security tokens" does not directly appear in Singapore's Guidelines for the Issuance of Digital Tokens and the Stock and Futures Act, they elaborate on the different circumstances in which tokens will be recognized as "capital market products":

(The above image is taken from "Guide to Digital Token Issuance" )

C. Hong Kong, China

The Securities and Futures Commission of Hong Kong has specific enumerated provisions regarding the positive and negative lists of securities in the Securities and Futures Ordinance.

(The above image is taken from the Securities and Futures Ordinance) )

The Regulation defines "securities" as structured products that include "shares, equity shares, notes and bonds", and does not restrict their existence in traditional carriers. The SFC has made it clear in the Circular on Intermediaries Engaging in Activities Related to Tokenized Securities that the nature of its regulatory targets is essentially traditional securities wrapped in tokenization.

D. United States

The U.S. Securities and Exchange Commission (SEC) stipulates that any product that passes the Howey Test is classified as a security. Any product identified as a security is subject to SEC regulation. The Howey Test is a legal standard established by the U.S. Supreme Court in the 1946 SEC v. W.J. Howey Co. case, used to determine whether a transaction or scheme constitutes an "investment contract," thereby making it subject to U.S. securities law regulation.

The Howey Test outlines four conditions under which a financial product is deemed a "security." The application of the Howey Test to digital assets is detailed in the SEC's Framework for "Investment Contract" Analysis of Digital Assets. We will proceed to conduct a detailed analysis on this matter:

The Investment of Money

It refers to investors injecting money or assets into a project in exchange for certain rights or expected returns. In the digital asset field, whether using fiat currency or cryptocurrency to purchase tokens, as long as there is a value exchange, it is generally recognized as meeting this standard. Therefore, most token issuances basically comply with this condition.

Common Enterprise

"Joint ventures" refer to a close binding of interests between investors and issuers, usually manifested as the investors' returns being directly related to the project's operational effectiveness. In token projects, if the returns of token holders depend on the business development of the project party or the operational results of the platform, it meets the characteristics of a "joint venture," and this condition is also relatively easy to establish in reality.

Reasonable Expectation of Profits Derived from Efforts of Others

This point is key in determining whether a token will be classified as a security token. The condition refers to the situation where if the purpose of investors purchasing the product is to expect future appreciation of the product or obtain other economic returns, and such returns are not derived from their own use or operational activities, but rather depend on the overall development of a project created by the efforts of others, then the product may potentially be regarded as a "security."

In the context of RWA projects, if the purpose of investors purchasing tokens is to obtain future appreciation or economic returns, rather than benefits derived from their own use or operational activities, then the token may have "profit expectations," thus triggering the determination of its securities attributes. Particularly when the token's returns are highly dependent on the professional operations of the issuer or project team, such as liquidity design, ecosystem expansion, community building, or cooperation with other platforms, this characteristic of "relying on the efforts of others" further strengthens its potential for securitization.

RWA tokens that have sustainable value in the true sense should be directly anchored to the real returns generated by the underlying real assets, rather than relying on market speculation, narrative packaging, or platform premiums to drive their value growth. If the value fluctuations of the tokens primarily originate from the "recreation" by the team or platform behind them, rather than changes in the returns of the assets themselves, then they do not possess the characteristics of "narrow RWA" and are more likely to be viewed as security tokens.

The introduction of the Howey test by the U.S. SEC in regulating crypto tokens means that it no longer relies on the form of the token to determine its regulatory stance, but instead shifts to a substantive review: focusing on the actual functions of the token, its issuance methods, and investor expectations. This change marks a trend towards stricter and more mature legal positioning of crypto assets by U.S. regulatory agencies.

What is the legal logic behind the "compliance" tiering of RWA projects?

After discussing so much about the concepts and definitions of RWA, let's return to the core question raised at the beginning of the article, which is also a common focus of concern within the industry:

As RWA has developed to this day, which types of RWA can be considered truly "compliant" RWA? How can we meet the compliance requirements for RWA projects in practice?

First, we believe that compliance means being regulated by local regulatory authorities and adhering to the provisions of the regulatory framework. In our understanding, the compliance of RWA is a layered system.

Layer One: Sandbox Compliance

This specifically refers to the Ensemble sandbox project designed by the Hong Kong Monetary Authority (HKMA), which is currently the narrowest and most regulatory pilot definition of "compliance." The Ensemble sandbox encourages financial institutions and technology companies to explore technological and model innovations in tokenization applications through projects like RWA in a controlled environment, to support its leading digital Hong Kong dollar project.

The Hong Kong Monetary Authority (HKMA) has demonstrated a high level of emphasis on the sovereignty of the future monetary system in promoting the central bank digital Hong Kong dollar (e-HKD) and exploring the regulation of stablecoins. The competition between central bank digital currencies and stablecoins is essentially a redefinition and contestation of "monetary sovereignty." The sandbox provides a certain degree of policy space and flexibility for project parties, which is conducive to promoting exploratory practices of bringing real assets onto the blockchain.

At the same time, the Monetary Authority is actively guiding the development of tokenized assets, attempting to expand their applications in real scenarios such as payments, settlements, and financing within a compliant framework. Several technology and financial institutions, including Ant Group, are members of the sandbox community, participating in the construction of the digital asset ecosystem. Projects entering the regulatory sandbox, to some extent, signify a higher level of compliance and policy recognition.

However, from the current situation, such projects are still in a closed operating state and have not yet entered the broad secondary market circulation stage, indicating that there are still actual challenges in terms of asset liquidity and market connectivity. Without a stable capital supply mechanism and effective secondary market support, the entire RWA token system is difficult to form a true economic closed loop.

Second layer: Hong Kong administrative regulatory compliance

As an international financial center, Hong Kong has been continuously advancing institutional exploration in the virtual asset field in recent years. As the first region in China to clearly promote the development of virtual assets, especially tokenized securities, Hong Kong has become a target market for many mainland project parties due to its open, compliant, and clearly defined regulatory environment.

By reviewing the relevant circulars and policy practices issued by the Hong Kong Securities and Futures Commission (SFC), we can easily find that the core regulation of RWA in Hong Kong is actually to incorporate it under the framework of STO for compliance management. Furthermore, the SFC has established a relatively comprehensive licensing system for Virtual Asset Service Providers (VASP) and Virtual Asset Trading Platforms (VATP), and is preparing to release a second virtual asset policy declaration, which will further clarify the regulatory attitude and basic principles when virtual assets are combined with real assets. Under this institutional framework, tokenization projects involving real assets, especially RWA, have been included in a higher level of compliance regulatory category.

From the current RWA projects that have been implemented in Hong Kong and have a certain market influence, most of these projects have clear securities attributes. This means that the tokens they issue involve ownership, income rights, or other transferable rights of real assets, which can constitute "securities" as defined under the Securities and Futures Ordinance. Therefore, these types of projects must be issued and circulated through the method of Security Token Offering (STO) in order to obtain regulatory approval and achieve compliance in market participation.

In summary, Hong Kong's regulatory positioning on RWA has become relatively clear: any mapping of real assets with securities attributes on the blockchain should be included in the STO regulatory system. Therefore, we believe that the current development path for RWA promoted by Hong Kong is essentially a specific application and practice of the securities tokenization (STO) path.

Layer 3: A clear regulatory framework in crypto-friendly regions

In regions with an open attitude towards virtual assets and relatively mature regulatory mechanisms, such as the United States, Singapore, and certain European countries, a more systematic compliance path has been established for the issuance, trading, and custody of crypto assets and their mapped real-world assets. RWA projects in such regions, if they can obtain the relevant licenses in accordance with the law and comply with information disclosure and asset compliance requirements, can be regarded as compliant RWAs operating under a clear regulatory framework.

Fourth Layer: "Pan Compliance"

This is the broadest sense of compliance, which is the opposite of "non-compliance". It specifically refers to RWA projects within certain offshore jurisdictions where the government temporarily adopts a "laissez-faire" attitude towards the virtual asset market, and it has not been clearly identified as violating or illegal. Its business model has a certain degree of compliance space within the local legal framework. Although the scope and concept of this compliance are relatively vague, and it does not yet constitute complete legal confirmation, it falls under the business status of "what is not prohibited by law is allowed" before legal regulations become clear.

In reality, we can observe that the vast majority of RWA projects actually find it difficult to comply with the first two types of regulations. Most projects choose to attempt the first three paths—namely, relying on the lenient policies of certain crypto "friendly" jurisdictions, trying to bypass sovereign regulatory boundaries to achieve formal "compliance" at a lower cost.

As a result, the RWA projects seem to be "popping up like dumplings", but the time for them to generate substantial financial value has not yet arrived. The fundamental turning point will depend on whether Hong Kong can clearly explore the secondary market mechanism for RWA—especially how to open up the cross-border flow of capital. If RWA transactions remain confined to a closed market targeting local retail investors in Hong Kong, both asset liquidity and the scale of funds will be extremely limited. To achieve a breakthrough, it is essential to allow global investors to invest in Chinese-related assets through compliant mechanisms, indirectly "buying the dip in China" in the form of RWA.

Hong Kong's role here can be compared to the significance of Nasdaq for global technology stocks back in the day. Once the regulatory mechanism matures and the market structure becomes clear, when Chinese people want to "go overseas" to seek financing and foreigners want to "bottom-fish" Chinese assets, the first stop will definitely be Hong Kong. This will not only be a regional policy dividend but also a new starting point for the reconstruction of financial infrastructure and capital market logic.

In summary, we believe that compliance for RWA projects must be conducted within the current framework, and all projects must maintain policy sensitivity. Once there are legal adjustments, urgent changes must be made. Given that the current regulatory environment is not yet fully clarified and the RWA ecosystem is still in the exploratory stage, we strongly recommend that all project parties proactively engage in "self-compliance" efforts. Although this means investing more resources and bearing higher time and compliance costs at the initial stage of the project, in the long run, it will significantly reduce systemic risks in legal, operational, and investor relations aspects.

Among all potential risks, fundraising risk is undoubtedly the most lethal hidden danger for RWA. Once a project design is deemed illegal fundraising, it will face significant legal consequences regardless of whether the assets are real or the technology is advanced, posing a direct threat to the project's survival and delivering a heavy blow to the company's assets and reputation. In the development of RWA, the definition of compliance will inevitably vary across different regions and regulatory environments. Developers and institutions must formulate a detailed phased compliance strategy based on their own business types, asset attributes, and the regulatory policies of their target markets. Only under the premise of ensuring controllable risks can the RWA project be steadily advanced.

Lawyer's advice on the RWA project

In summary, as a legal team, we systematically outline the core aspects that need to be focused on from a compliance perspective during the entire process of advancing RWA projects.

1. Choose a policy-friendly jurisdiction

In the current global regulatory landscape, the compliance advancement of RWA projects should prioritize jurisdictions with clear policies, mature regulatory frameworks, and an open attitude towards virtual assets, which can effectively reduce compliance uncertainty.

2. The underlying assets must possess real redeemable capabilities.

Regardless of how complex the technical architecture is, the essence of RWA projects is still to map the rights of real-world assets onto the blockchain. Therefore, the authenticity of the underlying assets, the reasonableness of their valuation, and the enforceability of the redemption mechanism are all core factors that determine the project's credibility and market acceptance.

3. Gain Investor Recognition

The core of RWA lies in asset mapping and rights confirmation. Therefore, whether the final buyer or user of off-chain assets recognizes the rights represented by the on-chain tokens is the key to the project's success or failure. This involves not only the individual willingness of investors but is also closely related to the legal attributes of the tokens and the clarity of rights.

While RWA project parties are promoting the compliance process, they must also face another core issue: investors must be informed. In reality, many projects package risks in complex structures, failing to clearly disclose the status of underlying assets or the logic of token models, leading investors to participate without a full understanding. Once fluctuations or risk events occur, it not only triggers a crisis of market trust but may also attract regulatory attention, making matters even more difficult to handle.

Therefore, establishing a clear mechanism for investor screening and education is crucial. RWA projects should not be open to all groups, but should consciously attract mature investors with a certain level of risk tolerance and financial understanding. In the early stages of the project, it is especially important to set certain thresholds, such as a professional investor certification mechanism, participation limits, and risk disclosure briefings, to ensure that entrants are "informed and voluntary," truly understanding the asset logic, compliance boundaries, and market liquidity risks behind the project.

4. Ensure that the institutional operators in the blockchain are compliant with regulations.

In the entire process of RWA, it often involves multiple stages such as fundraising, custody, valuation, tax processing, and cross-border compliance. Each stage corresponds to regulatory agencies and compliance requirements in reality, and project parties need to complete compliance declarations and regulatory connections under the relevant legal framework to reduce legal risks. For example, in the part related to fundraising, special attention should be paid to whether it triggers compliance obligations such as securities issuance and anti-money laundering.

5. Preventing Post-Compliance Risks

Compliance is not a one-time action. After the implementation of RWA projects, continuous adaptation to the changing regulatory environment is necessary. How to prevent potential administrative investigations or compliance accountability in the post-event dimension is an important guarantee for the sustainable development of the project. It is recommended that project parties establish a professional compliance team and maintain a communication mechanism with regulatory agencies.

6. Brand Reputation Management

In the highly sensitive virtual asset industry where information dissemination is critical, RWA projects also need to focus on public opinion management and market communication strategies. Building a transparent, trustworthy, and professional project image will help enhance public and regulatory trust, creating a favorable external environment for long-term development.

Conclusion

In the current process of the continuous integration of virtual assets and the real economy, various RWA projects have different intentions and mechanisms, featuring both technological innovations and financial experiments. The capabilities, professionalism, and practical paths of different projects vary greatly, making it worthwhile for us to study and categorize them one by one.

In the course of extensive research and project participation, we have also deeply realized that for market participants, the biggest challenge often does not lie in the technical level, but in the uncertainty of the system, especially the unstable factors in administrative and judicial practices. Therefore, what we need more is to explore the "practical standards"—even if we do not have legislative and regulatory power, promoting the formation of industry standardization and compliance in practice is still valuable. As long as there are more participants, mature paths, and regulatory agencies have established sufficient management experience, the system will gradually improve. Within the framework of the rule of law, facilitating cognitive consensus through practice and promoting institutional evolution through consensus is, for society, a form of "bottom-up" positive institutional evolution.

But we must also keep compliance as a constant alert. Respecting the existing judicial and regulatory framework is the basic premise for all innovative actions. Regardless of how the industry develops or how technology evolves, the law remains the underlying logic that guarantees market order and public interest.