Tokenization Services
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Asset Tokenization Services

End-to-End Commodity Tokenization Project Coordination

Gofaizen & Sherle provides commodity tokenization services that connect commodity assets, holder rights and provider responsibilities within one delivery plan. For businesses issuing tokenized commodities, coordination covers legal and regulatory support, custody arrangements and platform integration requirements. Each tokenized commodity needs a documented link between the token and the underlying assets.

Commodity Tokenization at a Glance

AreaQuestion to Resolve
Commodity tokenization modelWhat rights does each tokenized commodity represent?
Tokenized commoditiesWhat goods back the tokens, where are they stored, and what proves ownership?
CustodyWho stores the goods, and who safeguards the tokens?
ComplianceWhich requirements apply, and who must meet them?
PlatformHow will the platform issue and transfer tokens?
SettlementHow will payments, token transfers and redemption work?
MarketWhich investors and countries will the offering target?

Gofaizen & Sherle helps define the requirements and provider responsibilities in three areas:

  1. Custody Services

    Define separate responsibilities for physical commodity storage and digital token custody.

  2. Compliance Support

    Identify applicable requirements and clarify who is responsible for compliance before implementation begins.

  3. Platform Integration

    Agree integration and security requirements with technology providers and identify dependencies that affect delivery.

Who Is Commodity Tokenization For?

This service is for companies and platforms preparing a tokenized commodity offering backed by physical assets for retail or institutional investors:

  • Asset owners bringing identifiable commodities into a digital offering.
  • Issuers defining rights over physical assets and distribution markets.
  • Platforms adding commodity-backed products.
  • Businesses preparing custody and reporting arrangements for institutional investors.

Which Regulatory Checks Are Needed Before Launch?

Start with the legal rights attached to the commodity token. Regulatory classification identifies which rules, including securities rules, apply to the tokenized commodity. Then assess issuance, trading and other planned activities separately to identify regulated services, required permissions and compliance duties:

ActivityWhat to Check
IssuanceWhich offering rules apply, and does the issuer need authorization?
Secondary trading platformWhich permissions are needed to operate the market or arrange trades?
Digital custodyMust a regulated provider safeguard client tokens, and what duties apply?
Commodity storageWho owns the goods, and which local storage requirements apply?
SettlementDo payment and token-transfer arrangements require separate permissions?

What Work Does Commodity Tokenization Coordination Cover?

The checks above identify the applicable requirements. For tokenized commodities, coordination covers the practical arrangements for issuance, custody, settlement and redemption, plus secondary trading where planned:

  • Issuance documentation: connect token-holder rights with the records supporting each tokenized commodity.
  • Custody arrangements: agree who maintains physical storage and inventory records, safeguards tokens and authorizes asset release.
  • Settlement workflows: align payment processing with token transfers and transaction records.
  • Redemption procedures: document how holders submit requests and receive payment or delivery.
  • Secondary trading integration: coordinate platform integration and transfer restrictions with the technology provider.
  • Technical requirements: prepare smart contract requirements for external developers and security reviewers.

What Will Gofaizen & Sherle Handle?

Commodity tokenization services combine project coordination with legal and compliance support, including custody documentation and platform integration requirements.

Gofaizen & Sherle prepares the issuer structure and holder-rights documentation, involving local counsel where required.

Compliance Support

Gofaizen & Sherle defines onboarding and reporting requirements. Issuers and providers implement their assigned duties.

Custody Arrangements

Gofaizen & Sherle reviews contractual responsibilities. External custodians handle storage and safekeeping operations.

Integration and Delivery

Gofaizen & Sherle coordinates requirements and launch support. Technology providers build systems, while appointed specialists perform security reviews.

Why Work With Gofaizen & Sherle?

Gofaizen & Sherle connects legal structuring and compliance support for businesses considering institutional investors and global markets, including assessment of regulated provider roles.

Regulatory Expertise

Robert Pekin
Robert Pekin
Associate, Head of Tokenization

How Does the Commodity Tokenization Process Work?

The commodity tokenization process has six stages. The legal structure and applicable requirements guide development, onboarding and issuance:

Step 1 Define the asset and holder rights. Establish what the token represents and collect evidence of ownership.
Step 2 Set up the legal structure. Identify the issuer, asset holder and contractual relationships.
Step 3 Confirm regulatory classification. Determine applicable offering restrictions and required permissions.
Step 4 Agree custody and provider responsibilities. Assign storage, verification and technology tasks, including delivery conditions.
Step 5 Build and test the workflows. External technology providers implement integration, onboarding, token transfers and settlement arrangements.
Step 6 Confirm launch readiness. Check issuance conditions and assign responsibility for post-launch operations and reporting.

What Are the Commodity Tokenization Requirements?

Provide evidence of the underlying commodity, ownership, holder rights, inventory and custody arrangements in four input groups:

  • Underlying asset: specifications, location, inventory records, ownership documents, storage contracts and pledges.
  • Issuer: legal structure, beneficial owners and proposed token rights.
  • Distribution: target investors, markets, sales channels and existing AML/KYC arrangements.
  • Technology/providers: platform, wallet model, integrations and reporting interfaces.

What Determines the Delivery Timeline?

Timing depends on completing five milestones. Regulatory review, custody arrangements, provider onboarding and development can affect when delivery is possible:

Complete the asset evidence. Resolve missing ownership, storage and inventory records.

Confirm the regulatory route. Identify the applicable requirements and any authorization procedures that affect the schedule.

Complete provider onboarding. Agree custody arrangements, responsibilities and provider acceptance conditions.

Complete development and integration testing. Resolve technical issues and confirm that the connected workflows function as intended.

Close outstanding launch conditions. Confirm that the required documents, provider arrangements and operational checks are complete.

What Determines the Regulatory and Compliance Framework?

The applicable rules depend on what rights a tokenized commodity gives investors, where it is offered and whether the business handles issuance, trading or custody.

In the EU, the first legal question is whether the token qualifies as a financial instrument. If it does, MiCA Article 2 excludes it from MiCA, and the applicable securities framework must be assessed.

The issuer and each regulated service provider must then identify their own regulatory obligations, including applicable AML/KYC, reporting and other compliance duties.

What Is the Current Regulatory Status?

Commodity tokens have no universal regulatory status. These four examples show how applicable rules differ by jurisdiction.

Last reviewed: September 23, 2026.

Jurisdiction ExampleCurrent Regulatory Position
European UnionMiCA covers in-scope crypto-assets. Tokens qualifying as financial instruments fall under the applicable securities framework.
United StatesTokenized securities remain subject to securities laws. Commodity derivatives fall within the CFTC framework.
Dubai, excluding DIFCTokens qualifying as Asset-Referenced Virtual Assets fall under VARA’s specific issuance rules.

Which Compliance and Reporting Controls Continue After Launch?

Assign AML/KYC, custody, security and reporting responsibilities across issuer and provider operations to address applicable duties toward investors:

  • Maintain investor onboarding, required AML/KYC checks and monitoring.
  • Reconcile physical reserves and custody records with outstanding tokens.
  • Manage settlement exceptions and redemption operations.
  • Maintain security controls and incident procedures.
  • Deliver required disclosures and reporting.

Which Regulatory Risk and Compliance Risk Should Be Addressed?

Commodity backing does not guarantee a stable token price or repayment. Reserves may be insufficient, incorrectly valued or difficult to sell. Holders may face losses if the issuer or custodian fails, ownership rights are unclear, or redemption is delayed. Before buying, holders should understand what backs the token, how reserves are verified, and whether they can claim the commodity itself or only payment from the issuer.

Which Taxation Questions Need Separate Review?

Check how each relevant country taxes token sales, transfers of commodity ownership and redemption for cash or goods. Also check which financial and tax reports are required for the chosen legal structure. A token’s regulatory status does not, by itself, determine which taxes apply.

How Does Commodity Tokenization Compare With Other Models?

Commodity tokenization represents rights to a physical commodity through tokens. Compare a tokenized commodity with direct ownership and warehouse receipts:

ModelRights and CustodySettlement and AccessLegal Assessment
Tokenized commodityTokens may represent ownership or a claim against the issuer. Physical storage and token custody are separate arrangements.Eligible investors transfer tokens through supported wallets or platforms. Trading depends on available buyers and transfer restrictions.Check token classification, required permissions and whether holders can enforce their rights to payment or goods.
Direct holdingInvestors own physical assets and arrange storage themselves or through a provider.Buyers and sellers arrange payment and delivery or transfer of ownership. Market access depends on finding a trading counterparty.Check proof of ownership, storage contracts and transfer rules.
Warehouse receiptA receipt records rights to goods held by a warehouse. The document defines the holder’s rights.Where permitted, the receipt can be transferred while the goods remain in storage. Payment completes settlement.Check whether local law recognises the receipt, allows its transfer and protects the holder’s claim to the goods.

Frequently Asked Questions

Does a tokenized commodity protect me if the issuer fails?

Protection depends on enforceable ownership or contractual rights, segregation and applicable insolvency law. A blockchain balance alone cannot establish title to goods.

Can one provider handle physical and digital custody?

Potentially, but assess its capability, contractual responsibilities and permissions for each function separately.

Can redemption involve physical delivery?

Where the model and law allow it. For EU asset-referenced tokens, MiCA Article 39 provides for redemption through payment or delivery of referenced assets.

Does issuance secure exchange trading?

No. Admission requires a separate platform decision and assessment of distribution restrictions. Liquidity is not assured.

Can commodity tokenization target retail investors?

Gofaizen & Sherle can assess eligibility. Regulatory classification establishes which offering rules apply, then investor categories and target countries determine distribution restrictions.

Can existing KYC records be reused?

Each responsible provider must assess permitted reliance and whether records meet its AML/KYC obligations. Earlier onboarding is not automatic acceptance.

Can Gofaizen & Sherle coordinate an existing platform?

Yes. Gofaizen & Sherle can define legal and compliance requirements for the technology provider to assess integration needs and remaining gaps.

Mihhail Sherle
Mihhail Sherle
Senior Partner, Head of Legal
Robert Pekin
Robert Pekin
Associate, Head of Tokenization
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