BVI Gains Ground in Tokenised Treasuries and RWA Finance

Legasset Legal Blog Legal News BVI Gains Ground in Tokenised Treasuries and RWA Finance

BVI Gains Ground in Tokenised Treasuries and RWA Finance

British Virgin Islands structures now represent more than 10% of the global market for tokenised US Treasury products, according to new research published by BVI Finance.

The report links BVI structures to approximately $1.5 billion in distributed tokenised Treasury value as of 1 June 2026. It also identifies 305 tokenised securities and approximately $1.2 billion in stablecoin value associated with the jurisdiction.

These figures show how the BVI’s role is expanding beyond conventional holding companies, investment funds and cross-border corporate structures. BVI entities are increasingly appearing in products involving tokenised securities, government debt, stablecoins and other real-world assets.

The data does not mean that the underlying assets, investors or blockchain infrastructure are located in the BVI. In many cases, the jurisdiction provides the issuing, fund or holding vehicle within a wider international structure.

For tokenisation projects, this distinction is central. The legal entity, underlying asset, token-holder rights, custody arrangements and investor-facing regulations may each be governed by different jurisdictions.

For readers’ convenience, we have placed the key official sources and regulatory materials at the end of this article.

Publish Date

20 July 2026

Reading Time

15 minutes

Category

Legal News

Jurisdiction

British Virgin Island

BVI Finance reports rapid growth

BVI Finance released Destination Digital: An On-Chain Future during its Fintech on the Seas conference in June 2026.

The report attributes the following activity to BVI structures:

Reported metricPosition at 1 June 2026
Tokenised US Treasury valueApproximately $1.5 billion
Share of the global tokenised Treasury marketMore than 10%
Tokenised securities identified305
Stablecoin valueApproximately $1.2 billion
Stablecoin asset holders28,127
Weekly stablecoin transfer volumeApproximately $323.5 million

BVI Finance describes the 305 tokenised securities as the highest jurisdictional total in its dataset. It also annualises the reported weekly stablecoin transfer volume at more than $16.8 billion if the same activity level continues.

The figures require attribution

BVI Finance is responsible for promoting the jurisdiction’s financial services industry. Its findings are useful market indicators, but they are not equivalent to audited financial statements or official BVI FSC regulatory statistics.

The published methodology states that stablecoin market capitalisation, holder data and tokenised security values were sourced from RWA.xyz as of 1 June 2026.

The results may therefore depend on:

  • how entities are attributed to a jurisdiction;
  • which products qualify as tokenised securities;
  • how blockchain addresses are counted;
  • whether products use several legal entities;
  • whether distributed value means issuance, holdings or current market value; and
  • the reporting date used for each product.

The figures should be presented as findings from the BVI Finance study rather than a complete regulatory census.

Treasury value uses BVI structures

The report states that more than one in every ten dollars of tokenised US Treasury value is represented through BVI structures.

That is a significant corporate structuring footprint. It does not mean that 10% of US Treasury securities are held in the BVI or that 10% of tokenised Treasury trading takes place there.

Distributed value is not trading volume

The reported $1.5 billion concerns distributed tokenised Treasury value associated with BVI corporate structures.

It should not be interpreted as:

  • annual transaction volume;
  • assets held by BVI banks;
  • assets custodied physically or legally in the territory;
  • tax revenue generated in the BVI; or
  • capital belonging exclusively to BVI investors.

The BVI entity may be the fund, issuer, special-purpose vehicle or holding company. The underlying Treasury bills may be held through an international custodian outside the territory.

Tokens may represent fund interests

A token described as a tokenised Treasury does not always give its holder direct title to an identifiable US government security.

Depending on the product, the token may represent:

  • a share in a Treasury or money market fund;
  • an interest in a special-purpose vehicle;
  • a debt claim against an issuer;
  • a note backed by Treasury assets;
  • a contractual right linked to net asset value; or
  • a redemption claim against a product operator.

The legal rights arise from the instrument and its governing documents, not from the product’s marketing label.

Asset backing must be traced

A tokenised Treasury review should establish:

  1. Which entity issues the token.
  2. Which entity owns the underlying securities.
  3. Where the assets are custodied.
  4. Whether the assets are segregated.
  5. Whether token holders have proprietary or contractual rights.
  6. How subscription and redemption operate.
  7. What happens if the issuer becomes insolvent.
  8. Who can modify or suspend the smart contract.
  9. Which law governs the instrument.
  10. Where disputes can be enforced.

A reference to US Treasuries does not remove issuer, custody, liquidity or operational risk.

Stablecoin data needs precision

The study also associates approximately $1.2 billion in stablecoin value with the BVI.

This should not be restated as $1.2 billion of stablecoins issued by BVI companies. The available report summary does not establish that all of this amount represents issuance by BVI-incorporated stablecoin issuers.

Several relationships are possible

Stablecoin value may be associated with the BVI through:

  • a BVI-incorporated issuer or parent company;
  • a fund holding stablecoins;
  • a corporate treasury;
  • a special-purpose vehicle;
  • a trading or liquidity entity;
  • blockchain addresses attributed to BVI entities; or
  • a platform conducting services through a BVI company.

Each category has different legal implications.

An issuer may be responsible for reserve assets and redemption obligations. A corporate holder usually has no equivalent responsibility for the stablecoin itself.

Holder counts are not customer counts

The study identifies 28,127 stablecoin asset holders associated with the jurisdiction.

Blockchain data may count wallet addresses rather than verified beneficial owners. One legal person can control several addresses, while one custodial address can represent assets belonging to many customers.

The figure therefore indicates on-chain activity. It should not automatically be treated as the number of individual BVI stablecoin users.

Tether adds corporate context

The report notes that Tether Holdings Limited, the parent company associated with USDT, is incorporated in the BVI. It also refers to BVI entities within the corporate structures of other major digital asset businesses.

This helps explain the stablecoin figure, but does not by itself determine:

  • which entity legally issues each token;
  • where reserve assets are held;
  • which regulator supervises the product;
  • where customers contract;
  • where services are marketed; or
  • which consumer and payment rules apply.

Corporate domicile is only one part of the regulatory analysis.

Tokenised securities remain securities

The report identifies 305 tokenised securities connected with BVI structures.

Tokenisation changes how an instrument may be recorded, transferred or settled. It does not automatically change the instrument’s legal classification.

Rights determine the classification

A token may represent:

  • shares;
  • bonds or notes;
  • fund interests;
  • derivatives;
  • revenue participation;
  • asset-backed claims; or
  • another contractual investment.

Where the rights fall within the BVI definition of investments, the Securities and Investment Business Act and related legislation may apply.

The BVI FSC has warned that providing investment business of any kind in or from within the territory requires the appropriate authorisation.

Tokenisation does not remove offering rules

A BVI issuer may still need to assess:

  • whether the instrument is a security or fund interest;
  • whether the issuer constitutes a fund;
  • whether a private placement exemption is available;
  • whether an investment business licence is required;
  • which investors may participate;
  • what disclosures must be provided; and
  • whether marketing restrictions apply in each target country.

The investor’s jurisdiction may regulate the offering even where the issuing vehicle is incorporated in the BVI.

The legal register must match the token

Projects should determine whether the blockchain record is:

  • the definitive legal register;
  • a mirror of an off-chain register;
  • a record of a contractual entitlement; or
  • a technical settlement mechanism.

This affects when legal ownership transfers and which record prevails if the blockchain and corporate register diverge.

For tokenised BVI shares, the company’s memorandum, articles and statutory registers must be aligned with the technical system used to record token movements.

BVI companies offer flexible structures

The jurisdiction’s position in tokenised finance builds on its established corporate and investment business framework.

BVI business companies are widely used for asset holding, financing, joint ventures, investment funds and cross-border transactions.

Issuing vehicles

A BVI company can serve as the entity issuing tokenised shares, notes or contractual claims.

The constitutional and offering documents can define:

  • the rights represented by each token;
  • transfer restrictions;
  • voting rights;
  • distributions;
  • redemption procedures;
  • investor eligibility;
  • default events; and
  • enforcement mechanisms.

The smart contract should implement these provisions rather than create a conflicting parallel system.

Asset-holding vehicles

A BVI company may hold the asset backing a token or own interests in a subsidiary that holds it.

This can be useful for tokenised:

  • private debt;
  • real estate;
  • investment funds;
  • commodities;
  • intellectual property;
  • receivables; and
  • securities portfolios.

The structure must address legal ownership, asset segregation and the effect of insolvency at each corporate level.

Bankruptcy-remote SPVs

Some tokenisation projects use a special-purpose vehicle intended to isolate underlying assets from the operating business.

Corporate separation alone does not guarantee bankruptcy remoteness.

The documentation should address:

  • limited corporate purposes;
  • restrictions on additional debt;
  • independent governance where appropriate;
  • asset segregation;
  • security interests;
  • contractual non-petition provisions;
  • limited recourse;
  • cash-flow controls; and
  • replacement of service providers.

These protections must be legally effective in every relevant jurisdiction.

Fund vehicles

A tokenised structure may constitute a mutual fund, private investment fund or another regulated collective investment arrangement.

The analysis does not depend solely on whether the interests are called tokens. It depends on investor participation, pooling, investment management and the rights represented.

VASP regulation applies by activity

The Virtual Assets Service Providers Act, 2022 established the BVI registration and supervisory framework for businesses providing virtual asset services in or from within the territory.

The legislation came into force on 1 February 2023, with the BVI FSC acting as the competent supervisory authority.

Incorporation alone is not a VASP service

A BVI company does not automatically require VASP registration because it holds virtual assets or uses blockchain technology.

Registration depends on the activities conducted.

Potentially regulated services include:

  • exchange between virtual assets and fiat currency;
  • exchange between different virtual assets;
  • virtual asset transfers;
  • custody or administration;
  • operation of relevant trading platforms; and
  • specified financial services connected with an issuer’s virtual asset offering.

The complete product and service chain must be assessed. A company presented as an issuer may also provide custody, transfers or exchange functions.

Issuers require individual analysis

Issuing a token does not produce one universal regulatory result.

A project may fall:

  • within the VASP regime;
  • within securities and investment business legislation;
  • within fund regulation;
  • under several regimes simultaneously; or
  • outside licensing where no regulated activity is conducted.

The token’s rights and the issuer’s actual activities are more important than labels such as “RWA,” “utility token” or “digital security.”

VASP supervision is active

The BVI FSC’s 2026 compliance inspection programme identifies VASPs, investment businesses and trust and corporate service providers as higher-risk sectors.

The Commission announced plans to target 50 licensees during its 2026 inspection cycle, following 40 inspections in 2025.

The FSC’s Q1 2026 statistical bulletin also reports a thematic inspection involving a VASP licensee.

This indicates that BVI registration should not be treated as a passive incorporation exercise. Applicants and registered firms need operating controls that can withstand supervisory review.

Investment rules may apply alongside VASPA

The VASP framework does not replace the BVI’s existing financial services legislation.

A tokenised product may engage both virtual asset and investment business requirements.

Securities and fund analysis

The Securities and Investment Business Act regulates investment business carried on in or from within the BVI.

Depending on the structure, relevant activities may include:

  • dealing in investments;
  • arranging deals;
  • managing investments;
  • providing investment advice;
  • operating an investment exchange; or
  • administering investment products.

The BVI FSC’s current legislation library lists the revised Act, subsequent amendments and the 2024 amendment to its investment schedule.

Classification can overlap

A token may be both a virtual asset and an investment.

For example, a blockchain-based share can remain a security while also being transferred through virtual asset infrastructure. The issuer, manager, custodian and platform may each require a separate regulatory assessment.

Projects should avoid treating VASP registration as a substitute for investment business or fund authorisation.

AML controls remain central

Virtual asset businesses must operate within the BVI’s AML/CFT and counter-proliferation financing framework.

A public blockchain provides transaction data, but it does not automatically reveal the verified identity or beneficial owner behind every wallet.

Required controls

Depending on the business, the control framework may need to include:

  • customer due diligence;
  • beneficial ownership verification;
  • wallet screening;
  • transaction monitoring;
  • sanctions screening;
  • source-of-funds checks;
  • source-of-wealth checks;
  • suspicious activity reporting;
  • travel rule procedures;
  • geographic risk controls; and
  • record retention.

The BVI’s 2024–2026 national AML/CFT/CPF strategy identifies continuing work to strengthen risk-based supervision across the financial services sector.

Beneficial ownership filings

BVI companies and limited partnerships have also been subject to revised beneficial ownership filing requirements through the Registry of Corporate Affairs since 2 January 2025.

The FSC states that relevant entities must submit beneficial ownership information through the VIRRGIN system, subject to the applicable rules and exemptions.

Tokenisation does not remove these corporate transparency obligations.

Smart contracts need legal support

A technically functional token is not necessarily a legally enforceable financial product.

The code must reflect the rights granted under the issuer’s constitutional, contractual and offering documents.

Control rights must be disclosed

Investors should know who can:

  • mint new tokens;
  • burn tokens;
  • freeze wallets;
  • pause transfers;
  • change approved addresses;
  • upgrade the contract;
  • change oracles;
  • alter redemption functions; and
  • recover tokens after operational errors.

These functions can create material governance and counterparty risk.

Transfer restrictions must work

A private security may be subject to investor eligibility, sanctions, jurisdictional or lock-up restrictions.

Those limits should operate consistently across:

  • the smart contract;
  • the legal register;
  • the subscription agreement;
  • the offering memorandum;
  • the custody system; and
  • secondary trading venues.

A token transfer that occurs technically may not be legally valid if it breaches the governing documents or mandatory law.

Failure scenarios need documentation

The structure should address:

  • lost private keys;
  • mistaken transfers;
  • protocol exploits;
  • blockchain forks;
  • sanctions designations;
  • court orders;
  • custodian failure;
  • oracle failure;
  • issuer insolvency; and
  • termination of the product.

Code alone rarely resolves these issues.

Cross-border regulation still applies

A BVI vehicle is not a global regulatory passport.

Tokenised products are inherently cross-border because investors, managers, custodians, exchanges and underlying assets can be located in several jurisdictions.

Investor countries regulate distribution

An offering may trigger securities, financial promotion or virtual asset rules wherever investors are targeted.

A BVI issuer offering tokens into the EU, UK, United States, UAE, Singapore or another jurisdiction must assess the rules of that market.

Using a website, application or decentralised interface does not necessarily prevent the activity from being treated as targeted distribution.

Management location affects the structure

A BVI company may be managed by directors, investment managers or founders located elsewhere.

Their location can affect:

  • licensing;
  • tax residence;
  • permanent establishment;
  • economic substance;
  • regulatory supervision;
  • data protection; and
  • sanctions compliance.

The full operating model must therefore be reviewed, not only the place of incorporation.

BVI’s role is often structural

The BVI competes with the Cayman Islands, Luxembourg, Singapore, ADGM and DIFC for digital asset and tokenisation work.

The jurisdictions do not perform identical roles.

Multi-jurisdiction products are common

A tokenisation structure may use:

  • a BVI issuer or fund;
  • a UAE-licensed manager;
  • a European distributor;
  • a US custodian;
  • an Asian technology provider;
  • an offshore foundation;
  • a regulated exchange in another market; and
  • investors across several regions.

The BVI may provide the corporate or investment vehicle without hosting every regulated activity.

Regulatory quality will shape growth

Tax neutrality and flexible company law remain relevant, but they will not determine long-term market leadership on their own.

Institutional users will also assess:

  • regulatory supervision;
  • insolvency treatment;
  • asset segregation;
  • enforceability;
  • AML controls;
  • governance;
  • custody standards;
  • investor disclosures;
  • data reliability; and
  • access to regulated distribution.

The FSC’s active supervision of VASPs will therefore be as important as the number of entities incorporated.

Projects should review the full chain

A tokenisation project should map every entity, asset, service and jurisdiction before launch.

The review should establish:

  1. What legal right each token represents.
  2. Whether it is a share, debt instrument, fund interest or another claim.
  3. Which BVI entity issues or holds the asset.
  4. Whether VASP registration is required.
  5. Whether SIBA or fund regulation applies.
  6. Where the underlying asset is legally owned.
  7. Which custodian holds the asset.
  8. Whether the asset is segregated from the issuer.
  9. Whether the blockchain record establishes legal title.
  10. How token holders redeem or enforce their rights.
  11. Which investor jurisdictions are targeted.
  12. Whether private placement exemptions are available.
  13. How AML/KYC and wallet screening operate.
  14. Who controls minting, freezing and smart contract upgrades.
  15. How insolvency, errors and lost keys are handled.
  16. Whether BVI beneficial ownership filings are complete.
  17. Whether economic substance and tax requirements apply.
  18. Whether the structure can access banking and fiat settlement.

A weakness at any level can undermine the product, even where the BVI vehicle itself has been properly incorporated.

BVI’s digital finance role is expanding

The BVI Finance study provides credible evidence that BVI entities are being used extensively in tokenised Treasury, stablecoin and digital security structures.

Its strongest finding is structural: approximately $1.5 billion in tokenised US Treasury value was represented through BVI entities as of 1 June 2026.

The data does not establish that every underlying asset, regulated service or investor relationship is located in the territory. Nor does it prove that BVI entities issued all $1.2 billion of stablecoin value associated with the jurisdiction.

The BVI’s position is better understood as a legal and corporate layer within an international tokenisation market.

Its combination of established company law, investment structures and a dedicated VASP regime creates a useful platform for digital finance. The quality of licensing, supervision, disclosure and cross-border compliance will determine whether that position remains sustainable.

Legasset supports tokenisation projects, fund sponsors and digital asset businesses with BVI entity structuring, regulatory perimeter analysis, VASP registration planning, securities classification, offering documentation and cross-border market entry. Complex structures should be coordinated with BVI counsel and advisers in each investor-facing jurisdiction.

FAQ: BVI Tokenised Finance and RWA Structures

Does the BVI control 10% of tokenised US Treasuries?

BVI Finance reports that more than 10% of global tokenised US Treasury distributed value was represented through BVI structures on 1 June 2026.

This does not mean that the underlying Treasuries are held in the BVI or that 10% of global trading takes place there.

The study reports approximately $1.5 billion in distributed tokenised US Treasury value.

The figure should be attributed to BVI Finance and read in the context of its RWA.xyz-based methodology.

The published summary does not clearly establish that all $1.2 billion represents stablecoins issued by BVI entities.

It associates that amount of stablecoin value with the jurisdiction. Issuance, corporate holdings, treasury assets and blockchain activity must be distinguished.

BVI Finance reports that its dataset identified 305 tokenised securities connected with BVI structures.

The number does not necessarily mean that all 305 products were licensed, approved or registered as securities by the BVI FSC.

Not automatically.

Registration depends on the services conducted. Exchange, transfer, custody, platform operation and certain issuer-related services may fall within the VASP regime.

Yes.

A token representing shares, debt, fund interests or comparable investment rights may fall within securities and investment business legislation.

Not necessarily.

A business may need separate authorisation under the Securities and Investment Business Act or fund legislation. The regimes can apply simultaneously.

A BVI company can form part of an international issuance structure.

It must still comply with securities, virtual asset, financial promotion and investor protection rules in every jurisdiction it targets.

No.

The underlying government debt may have low credit risk, but the product can still create issuer, custody, liquidity, smart contract, redemption and insolvency risks.

Not always.

The token may represent a fund share, note, SPV interest or contractual claim rather than direct ownership of an identifiable Treasury security.

The issuer should document legal title, token-holder rights, asset custody, segregation, redemption, insolvency treatment, transfer controls and the relationship between the blockchain record and the legal register.

Topic-Specific Official Resources and Regulatory Materials

I. BVI Finance — BVI emerges as a global hub for tokenised finance
BVI Finance announcement dated 23 June 2026 setting out the principal findings from Destination Digital: An On-Chain Future, including tokenised Treasury value, stablecoin activity and tokenised securities associated with BVI structures.

II. BVI Financial Services Commission — Virtual Assets Service Providers Act, 2022
Official legislation establishing the registration and supervision framework for businesses providing virtual asset services in or from within the British Virgin Islands.

III. BVI Financial Services Commission — VASP Act commencement and regulatory framework
Official FSC notice confirming the role of the Commission as the competent authority for VASPs and the commencement of the BVI virtual asset regulatory framework on 1 February 2023.

IV. BVI Financial Services Commission — Guidance on the regulation of virtual assets
FSC guidance explaining how virtual asset activities may interact with existing BVI financial services legislation, including securities, investment business and virtual asset requirements.

V. BVI Financial Services Commission — Securities and Investment Business Act
Official text of the principal BVI legislation governing investment business, securities activities and regulated investment products, subject to subsequent amendments and statutory instruments.

VI. BVI Financial Services Commission — Compliance inspection priorities for 2026
Official FSC release identifying VASPs, investment businesses and trust and corporate service providers among the higher-risk sectors targeted during the Commission’s 2026 inspection cycle.

VII. BVI Financial Services Commission — Virtual assets and VASP regulatory FAQs
Official FSC publication addressing virtual asset definitions, VASP registration, AML/CFT exposure and practical questions arising under the BVI regulatory framework.

VIII. BVI Financial Services Commission — Beneficial ownership filing requirements
Official FSC update on beneficial ownership filings by BVI business companies and limited partnerships through the Registry of Corporate Affairs and the VIRRGIN system.

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