2.2 Dual-Chain Architecture

For tokenizing Chinese-origin assets, many projects adopt a dual-chain architecture:

1. Onshore Anchoring Phase:

• Business and yield data are anchored on permissioned chains such as AntChain or Spark Chain;

• Compliance often involves regulatory sandbox participation and third-party audits.

1. Offshore Issuance Phase:

• A Hong Kong-based SPV or fund structure is established to legally host the offshore asset rights;

• Tokens are issued on a public chain such as Ethereum or Polygon and distributed to qualified investors.

Qualified investor participation requires meeting the following minimum conditions:

• An active account at a Hong Kong-based licensed bank;

• Proof of assets exceeding HKD 8 million, verifiable through a broker, bank, or trust company;

• Use of regulated distribution channels (e.g., Type 9 licensed fund managers, brokers, or private banks supporting RWA product placements).

Once issued, the asset ownership exists as tokenized rights on a public chain, while the legal yield entitlement is held by the SPV. This structure allows cross-border sale and transfer to qualified global investors under local regulatory frameworks.