Author: Brian, Guitian Laboratory W Labs

(Continuing from Part One) “Hong Kong RWA Storm (Part One): From Frenzy to Reconstruction, Analyzing the Strengths of the Nine Major Factions”

7. AlloyX —— A “Hybrid Aggregator” Connecting DeFi Liquidity with Real Assets

In the grand narrative of Hong Kong RWA, if HashKey and OSL are building “heavy asset” infrastructure similar to Nasdaq or bank vaults, then AlloyX represents another agile force in the RWA market — a “DeFi Native Aggregator.”

As a Web3 financial technology company originating from San Francisco and fully acquired by Hong Kong-listed broker Solowin Holdings (NASDAQ: SWIN), AlloyX plays a unique role in Hong Kong’s RWA landscape as a “CeDeFi (Centralized and Decentralized Hybrid Finance) Connector.” It does not directly hold heavy physical assets but instead uses smart contract technology to “pack” credit assets scattered across different chains and protocols into high-liquidity financial products, delivering them directly to investors in the crypto world.

AlloyX’s business logic is fundamentally different from traditional exchanges. It is essentially an RWA Asset Aggregation Protocol (Aggregator Protocol).

In the early RWA market, assets were fragmented: investors wanting to buy US bonds might need to go to one platform, private credit to another, with very high thresholds. AlloyX’s emergence solves this pain point. It has built a modular “Vault” system capable of integrating assets from upstream credit protocols like Centrifuge, Goldfinch, Credix, and others. By standardizing these into unified tokenized products, AlloyX allows users to easily allocate stablecoins like USDC into real-world credit assets, just like depositing into Yu’e Bao.

With its formal integration into Solowin Holdings in 2025, AlloyX has completed a glamorous transformation from a “pure DeFi protocol” to a “compliant FinTech flagship.” Today, AlloyX is more like a tentacle of Solowin, a traditional broker reaching into the Web3 world, leveraging Hong Kong’s regulatory licenses to distribute traditional securities, funds, and other assets as tokens to global investors, achieving a true “Asset rights confirmed in the traditional world, liquidity released on the blockchain.”

In Hong Kong’s highly competitive market, AlloyX’s moat mainly lies in the combination of its unique shareholder background and technical architecture.

First, the backing and resource injection from a listed company is its biggest differentiator. As a wholly owned subsidiary of Nasdaq-listed Solowin, AlloyX avoids the compliance dilemmas faced by ordinary DeFi projects. It can directly utilize its parent company’s licenses from the Hong Kong Securities and Futures Commission (SFC) — Classes 1, 4, and 9 — to legally design and distribute tokenized products with securities characteristics. This “front-end DeFi experience + back-end licensed broker risk control” model aligns perfectly with Hong Kong’s regulatory direction of CeDeFi.

Second, AlloyX possesses strong “asset composability” technology. Unlike single-asset issuers, AlloyX excels at algorithmically blending RWA assets of different risk levels (e.g., low-risk US bonds and high-risk trade finance) into structured on-chain products similar to structured notes. This capability enables institutional investors to customize RWA portfolios on-chain according to their risk preferences, greatly enriching profit strategies in the RWA market.

AlloyX’s core business practices focus on “asset aggregation” and “compliant issuance.” Here are some of its most representative cases:

Looking back at AlloyX’s development path, it’s clear that it does not pursue large-scale platform traffic but concentrates on refined asset-side operations. Through its acquisition by Solowin, AlloyX has effectively become a “technology engine” for traditional financial institutions’ digital transformation of RWA. For the market, AlloyX proves that RWA is not just a game for giants; technical protocols deeply integrated with licensed institutions can also find a core ecological niche within compliant walls.

8. Asseto —— A “Asset Encapsulation Factory” Designed for Institutions

In Hong Kong’s RWA industry chain, Asseto plays a key role as the “asset source.” It is positioned at the top of the industry chain, directly interfacing with the real economy.

As a flagship RWA infrastructure project strategically invested by HashKey Group, Asseto boasts a “prestigious pedigree.” It does not deal directly with retail investors but focuses on solving the “first mile” challenge of RWA: how to transform a building or a fund into a compliant token from legal structure, technical standards, and compliance processes.

Asseto’s business model is highly vertical and high barrier, mainly serving TradFi giants with assets worth billions:

• RWA Asset Issuance Gateway: Asseto provides a standardized tech stack that allows institutions to “on-chain” assets like cash management products, real estate, private credit, etc., with one click. It not only offers smart contracts but also provides “legal packaging” services to ensure that tokens on-chain have real claim rights to underlying assets under Hong Kong law.
• HashKey Ecosystem’s “Asset Conveyor Belt”: As an invested company of HashKey, Asseto is a potential source of RWA assets for HashKey Exchange. It handles off-chain asset organization (cleansing, rights confirmation, tokenization) and then distributes these via HashKey’s compliant channels to secondary market investors.
• Application Scenario Provider for Stablecoin Sandbox: Asseto collaborates closely with multiple institutions applying for Hong Kong stablecoin licenses, aiming to use RWA assets as reserves for stablecoins, exploring high-end methods like “issuing stablecoins backed by tokenized government bonds/cash.”

The core advantage of Asseto in Hong Kong’s market is its top-tier resource support from its shareholder structure:

• HashKey’s technological and channel support: HashKey not only funds Asseto but also opens HashKey Chain )L2 public chain ( as the preferred issuance platform. This means assets issued by Asseto inherently have Hong Kong’s largest compliant liquidity outlet.
• Asset injection from DL Holdings )De Lin Holdings (: Hong Kong Main Board-listed DL Holdings )1709.HK( has invested in Asseto and signed strategic agreements to tokenize its family office assets (such as commercial real estate, fund shares). This solves the “asset scarcity” problem in RWA projects — Asseto starts with high-quality assets from a listed company.

Asseto’s case is highly “institutional customized,” mainly focusing on real estate and cash management:

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Asseto is Hong Kong’s “asset alchemist” in the RWA market. It does not directly target retail consumers but operates behind the scenes, using precise legal and technical molds to transform large, cumbersome assets of traditional financial institutions into circulating coins suitable for Web3.

)# 9. FireX —— An “Industrial-Grade” RWA Platform Releasing Computing Power Liquidity

In Hong Kong’s RWA market, most platforms handle “paper assets” (like bonds, equities), but FireX focuses on “production assets.”

FireX is an institutional-grade RWA trading platform with the core narrative of “financializing Bitcoin’s source capacity (hashpower).” It collaborates with top infrastructure providers like Bitmain to encapsulate data centers and mining machines located globally (USA, Canada, Kazakhstan, etc.) into tradable on-chain RWA tokens. For investors, purchasing FireX’s RWA products is essentially buying a “future cash flow right” of a running supercomputer.

FireX’s business logic is highly vertical, solving the mismatch of “poor liquidity” in traditional mining and “lack of stable physical yields” in Web3:

• Hashpower Assetization: FireX converts physical-world mining machines (like S21e Hyd miners with 288 TH/s) and their hashpower into on-chain assets. Users don’t need to build or maintain mining farms but can hold hashpower and earn Bitcoin mining rewards.
• Global Energy Arbitrage Network: FireX is more than a trading platform; it’s backed by a vast physical infrastructure network. It owns or partners with over 30 data centers in Texas, Quebec, Ethiopia, and more. It essentially conducts global energy arbitrage — finding the cheapest electricity, converting it into Bitcoin, and distributing yields via RWA.
• Diversified Asset Allocation Entry: Besides core Bitcoin hashpower, FireX’s vision includes tokenized global stocks (like NVDA, MSFT), pre-IPO equities, and AI computing assets. It aims to create a “comprehensive asset basket covering digital and physical worlds.”

Unlike pure software protocols, FireX’s moat is built on heavy “hardware” and “ecosystem relationships”:

• Verifiable physical scale: FireX has deployed over 5,000 supercomputing servers, managing over 1,000 PH/s hashpower, with on-chain assets exceeding $20 million. This tangible scale provides the bottom-line credit endorsement for RWA — ownership rights belong to clients, and assets are genuinely operational.
• Top-tier ecosystem network: According to disclosures, FireX’s partners include mining giant BITMAIN, mining pool Antpool, and major institutions like Binance, Coinbase, Tether. This full-chain resource integration from mining machine production, mining, trading, to stablecoins ensures stable asset supply and low-cost advantages (e.g., zero machine placement fees, zero service fees).
• High-yield product design: During Bitcoin bull cycles, FireX’s hashpower RWA shows high yield elasticity. Based on calculations for its S21e Hyd product, with Bitcoin reaching $150,000, ROI could approach 100%. This is more attractive than traditional sovereign debt RWA.

FireX’s business is highly focused on “hashpower financialization” and “global asset allocation”:

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FireX is a “hardcore industrial” in the RWA track. It breaks away from simply “repackaging” traditional financial assets like bonds, instead securitizing Bitcoin hashpower — a native digital asset — providing a fundamental yield layer supported by real machines and electricity consumption.

Dual Narrative: Deep Benchmarking of Hong Kong and US RWA Markets

If 2024 is the year of concept validation for RWA, then 2025 will be the year of “bipolar” shaping of the global RWA landscape. In the global RWA map, the US and Hong Kong represent two completely different yet mirror-image development paths.

The US relies on its native DeFi innovation and dollar hegemony to become a “Super Factory” for RWA assets; Hong Kong, leveraging its unique institutional advantages and geopolitical positioning, becomes a “Super Boutique” and “Distribution Hub” for RWA assets.

)# 1. Regulatory Philosophy: “Enforcement Tolerance” vs. “Sandbox Access”

USA: Bottom-up Jungle Law

The US RWA market has grown wildly in regulatory gaps. Although regulation softened somewhat after Trump’s administration took office in 2025, the core logic remains “Regulation by Enforcement” and “DeFi First” contest.

• Features: US projects (like Ondo, Centrifuge) often start as DAOs or decentralized protocols, prioritizing scale and technological innovation, then use complex legal structures (e.g., offshore SPVs) to evade SEC securities classification.
• Advantages: Rapid innovation, can implement asset portfolios via smart contracts without licenses, easily produce phenomena like BlackRock BUIDL with strong scale effects.
• Disadvantages: Legal gray areas are large; involving cross-border distribution or retail investors entails high compliance risks.

Hong Kong: Top-down Design

Hong Kong takes the opposite route — a “Licensing Regime.” From HashKey obtaining an exchange license to Star Road (Xinglu Technology) relying on Fosun Wealth’s Class 1, 4, 9 licenses, every step of Hong Kong RWA is within the scope of the SFC and HKMA.

• Features: “No license, no RWA.” All projects (like OSL, HashKey) must operate within the Project Ensemble sandbox or existing securities frameworks. Regulators are not just referees but also “product managers” (e.g., guiding tokenized deposit design).
• Advantages: Very high certainty. Once approved (e.g., Huaxia Fund’s tokenized product), they can legally connect with banking systems and retail funds, with trust backing comparable to traditional financial institutions.
• Disadvantages: High entry barriers and compliance costs (over $800,000 USD per project), suppressing grassroots innovation, leading to market participants mainly being “elite” or “conglomerates.”

2. Market Structure: “Pure DeFi” vs. “Traditional Conglomerates”

USA: DeFi-native Capital’s Main Stage

The US RWA market structure is “DeFi compatible with TradFi.” Main capital sources include whale-sized USDC/USDT on-chain, DAO treasuries, and crypto hedge funds. Project teams are usually tech geeks who disdain cumbersome offline processes, aiming to turn everything (including sovereign bonds) into ERC-20 tokens and deposit them into Uniswap or Aave for collateralized lending.

• Typical Image: Protocols like MakerDAO or Compound buy US bonds via RWA modules to support stablecoin yields.

Hong Kong: Traditional Conglomerates’ Digital Transformation

Hong Kong’s RWA market structure is “TradFi adapting to Web3.” Main capital comes from family offices, high-net-worth individuals (HNWIs), and corporate treasuries seeking diversification. Project teams often have deep industry backgrounds (e.g., FireX’s mining capacity, Star Road’s Fosun industrial capital, Asseto’s real estate funds).

• Typical Image: Star Road’s “Web5” strategy — using Web3 tech to serve existing Web2 clients. Hong Kong RWA is not about creating new assets but about making “old money” feel innovative and safe.

3. Asset and Project Spectrum: “Standardized Treasuries” vs. “Non-standard Structured Assets”

USA: Dominance of US Treasuries

About 80% of TVL in US RWA is concentrated in “Tokenized US Treasuries.” These are the most standard, liquid, and easily accepted collateral in DeFi protocols. US RWA projects often focus on fee arbitrage and T+0 settlement.

Hong Kong: Experimental Field for Diverse Assets

Limited by market size, Hong Kong cannot compete with the US in pure US Treasury space, so it moves toward “Differentiation” and “Physicalization.”

• Physical and Industrial RWA: FireX packages Bitcoin hashpower and energy into RWA, a Hong Kong-specific “hardcore industrial” innovation leveraging Asia’s advantage in global mining supply chains.
• Real Estate and Alternative Assets: Mantra (though headquartered in Dubai, deeply involved in Asia) and Asseto focus on real estate, private credit, and other non-standard assets. Hong Kong is better at handling complex offline rights confirmation (e.g., Star Road’s Fosun assets).
• Infrastructure: OSL and HashKey do not just handle assets but build “Exchange + Custody + SaaS” full infrastructure, reflecting Hong Kong’s service-oriented financial center DNA.

Recommendations for Mainland Assets and Enterprises Going to Hong Kong for RWA

Given recent regulatory tightening, for enterprises with mainland backgrounds (shareholders, teams, operational entities), the window for issuing RWA via “Mainland assets/teams + Hong Kong shell” has essentially closed. This is not just a compliance challenge but a shift from “gray area” to “high criminal risk.”

On November 28, 2025, a central bank and 12 other departments’ meeting explicitly stated that stablecoins are virtual currencies, not legal tender, and related activities are illegal financial activities. This effectively cuts off the core “payment settlement” leg of RWA. RWA yields are usually settled in stablecoins (USDT/USDC), which is now considered illegal. On December 5, 2025, seven industry associations issued risk warnings, explicitly listing RWA investment and financing as illegal activities, akin to illegal public fundraising.

Under this policy environment, mainland enterprises issuing RWA in Hong Kong face three levels of barriers:

A. The “Long Arm” of Jurisdiction (Piercing Regulation)

The previous approach was: set up an SPV (special purpose vehicle) in Hong Kong, with the mainland parent providing tech support or consulting. Now, this “隔离墙” (barrier) has failed.

• Personal jurisdiction: Even if the issuer is in Hong Kong, if the actual controller, senior executives, or technical team are in mainland China, under new regulations, they are considered “cooperating with illegal financial activities.”
• Helper risk: The December policies emphasize cracking down on the entire industry chain. Mainland entities (and individuals) providing technical development, marketing, payment settlement, or market-making services for offshore RWA projects may violate the “Illegal Business” or “Help Information Network Crime” (assist in crime) clauses of the Criminal Law.

B. Asset Side “Supply Cut”

Hong Kong RWA market most desires high-quality mainland real assets (e.g., photovoltaic project rights, commercial real estate rents).

• Asset export restrictions: Since RWA is deemed illegal financial activity, packaging domestic assets for offshore financing via RWA is suspected of illegal foreign exchange and capital flight.
• Rights confirmation dilemma: Domestic law does not recognize on-chain tokens’ ownership of domestic assets. If a project defaults, overseas investors holding tokens cannot enforce assets in mainland courts (due to violation of public order and mandatory provisions).

C. Capital Side “Containment”

• Funds flow blocked: Even if you raise USDT/USDC in Hong Kong, these funds cannot be legally remitted back to mainland entities for real economic activities (banks will refuse “virtual currency-related” funds).
• Marketing red line for mainland investors: Strictly prohibit marketing to Chinese citizens. If your RWA product PPM has a Chinese version or your roadshow involves mainland IP, it will trigger regulatory red lines.

Market feedback since November 28 shows that the Hong Kong RWA market has reacted strongly. About 90% of RWA projects with mainland backgrounds have been suspended or canceled. Hong Kong-listed companies related to RWA concepts (especially those with parent companies in mainland China, e.g., Meitu, Xinhuo Technology, Boya Interactive) have seen significant stock price declines.

Therefore, pure mainland-background enterprises (Team in China, Assets in China) still wanting to participate in RWA token issuance face extremely high risks: non-compliance and potential criminal liability. It is recommended to abandon RWA tokenization narratives and revert to traditional ABS (asset securitization) or issue traditional bonds in Hong Kong.

For fully outbound companies (Global Team, Global Assets), it is theoretically still feasible but requires segmentation, including physical and legal separation, such as:

• Personnel separation: Core teams and private key controllers cannot be in mainland China.
• Asset separation: Underlying assets must be overseas (e.g., US bonds, overseas real estate), not domestic assets.
• Market separation: Strict KYC, use technical means to block mainland IPs, and avoid any Chinese-language promotion.

Conclusion and Outlook: Returning to the “Original” Path from the “Frenzy” — The Hong Kong Route

Looking back at 2025, Hong Kong’s RWA market experienced an almost brutal stress test. From the initial widespread attention at Project Ensemble, to the mid-year frenzy of capital inflows, and finally to the freezing and restructuring triggered by tightened mainland regulation at year-end, this process, though painful, completed a deep reshuffle of the market.

After the big waves, the speculators who swam naked retreated, leaving behind the seven pillars we analyzed in depth:

• HashKey and OSL maintained the bottom line of compliant trading and custody, becoming Hong Kong Web3’s “utilities”;
• Star Road and Asseto proved the feasibility of traditional conglomerates revitalizing existing assets through RWA;
• FireX demonstrated Hong Kong’s unique ability to connect real industries (hashpower/energy) with digital finance;
• Mantra and AlloyX provided essential underlying public chains and DeFi liquidity aggregation.

Looking ahead to 2026, three major trends are expected in Hong Kong’s RWA market:

1. “Internal cycle” shifting to “External cycle”: As mainland capital channels tighten, Hong Kong will fully abandon the “helping mainland capital go abroad” gray area. Future growth will mainly come from “Global assets, Hong Kong distribution,” i.e., packaging US bonds, Dubai real estate (like Mantra), or global hashpower (like FireX) for institutional investors in Southeast Asia, Middle East, and Japan/Korea. Hong Kong will become a true “Offshore Financial Router.”

2. The boundary between RWA and DeFi dissolves (CeDeFi): Pure “asset on-chain” is no longer profitable. The next phase’s core competition is “composability.” We will see more aggregators like AlloyX, using tokenized funds issued by Star Road as collateral to generate stablecoins or leverage on-chain. Compliant CeFi assets will become the best “Lego blocks” for DeFi protocols.

3. Stablecoins as the ultimate battlefield for RWA: All RWA transactions and settlements ultimately point to currency. With the implementation of Hong Kong stablecoin regulations, “Interest-bearing stablecoins” (backed by RWA assets) will become the largest RWA single product. Whoever masters the issuance scenarios of RWA (e.g., FireX’s mining yield settlement, Asseto’s real estate rent distribution) will control the minting of HKD/USD stablecoins.

The story of Hong Kong RWA is not over; it has only just passed the “grassroots entrepreneurship” chapter and entered the “institutional game” phase. In this new stage, compliance is no longer a burden but the greatest asset; technology is no longer a gimmick but a carrier of credit. Hong Kong, a city constantly evolving through crises, is redefining its role as a financial hub in the digital age.