Fractional Ownership.Real Asset Returns.VARA-Regulated Infrastructure.
Legacy28 connects verified participants with fractional economic exposure to real-world assets — prime real estate, agricultural programmes, commodity structures, and carbon credit portfolios through a VARA-licensed, escrow-anchored platform.
Capital is at risk. No guaranteed return is offered or implied. Seek independent financial advice before participating.
A six-stage process. Governed and recorded at every step.
From identity verification to structured exit, every stage is compliance-gated, escrow-anchored, and creates a permanent on-chain record.
What makes this structurally different
Compliance is embedded in the token contract through the identity standard. Anonymous transfers are not possible because the receiving identity is checked on every transfer.
Tokens are minted only on confirmed settlement of a subscription order through the three-vendor UAE rail — card processing via network.AE, crypto on-ramp via changer.AE, and segregated escrow held at MBank — or a supported stablecoin rail. Supply is structurally bounded by paid-in capital.
The on-chain token balance, the legally binding subscription agreement, and the project record in the underlying asset's governance structure — three separate systems reconciled daily.
The platform operates a single-venue agency execution model under its VARA Broker-Dealer authorisation. Participants submit Expressions of Interest; the Over the Counter Desk prepares match proposals against a published reference price (VWAP → NAV → independent valuation). Both counterparties confirm, six pre-settlement checks run, and settlement executes sequentially with the token leg first and the cash leg second.
No single holder may own more than 20% of the project supply. The cap is enforced at the contract level on every transfer. Confirmed owner carve-outs are documented in the project whitepaper.
VARA-regulated. KYC enforced at the contract level. Daily automated reconciliation. Independent smart contract audit before launch. Designed for the regulatory environment it operates in.
Building the infrastructure for compliant fractional real-world asset ownership
Legacy28 Global is a VARA-regulated Virtual Asset Broker-Dealer and Asset-Referenced Virtual Asset Issuer operating from the DMCC Free Zone in Dubai. The platform gives verified participants fractional economic exposure to real-world assets — real estate, agriculture, commodities, and carbon credits. Every token issued is backed by a segregated reserve asset, independently audited twice yearly, and governed through a multi-party SPV structure.
Every project listed holds its underlying asset within an appropriate governance structure for that asset class. Participant positions are confirmed in three independent systems — on-chain, contractual, and in the project's governance record — reconciled every day.
Compliance is embedded in the architecture itself. Every design decision was stress-tested against one question: can this be bypassed?
Daily reconciliation. Annual independent audit. On-chain records accessible to participants.
Three independent records confirm every position. No single party including Legacy28 can alter a participant's position unilaterally.
Proactive VARA engagement. Products structured to exceed minimum requirements.
Every document, process, and governance body operates to the standards of a licensed entity.
Every architectural decision was made for a multi-decade operating horizon. This is infrastructure, not a product cycle.
Mission
To give sophisticated participants across the GCC and beyond a credible, regulated pathway into real-world asset returns — from prime real estate and productive agricultural land to commodity structures and carbon credits. We operate at institutional standards because our participants expect nothing less.
Vision
To be the platform that defines what institutional-grade real-world asset tokenisation looks like in the MENA region. Not the loudest, not the fastest to market — the most trusted. Built on the principle that if the compliance architecture is sound, everything else follows.
- Participant identity embedded at the token level, not the application layer
- Every token backed by a verified, confirmed escrow deposit
- SPV governance with independent administrators and formal corporate registers
- Three independent records confirm every participation position
- Agency-execution secondary market via the Over the Counter Desk, with external liquidity providers participating as standing-EOI counterparties
- Daily automated reconciliation anchored on-chain
- Annual independent external audit of all platform operations
A VARA-regulated tokenisation platform built around fractional economic exposure to real-world assets
Legacy28 Global is a VARA-licensed platform that gives verified participants fractional economic exposure to real-world assets through a single-token architecture. Each project issues its own ERC-3643 Participation Token. Every position is fully reserved, independently audited, and confirmed across three separate records.
Every project on the platform issues its own Participation Token. A Participation Token represents a direct asset-linked entitlement to the economic performance of the project's underlying asset. There is no platform-wide deposit token, no platform-level redemption token, and no platform recognition token.
Every Participation Token is an ERC-3643 token under the identity standard. The standard binds the holder's verified identity to the token at the protocol level through an on-chain identity contract and a claims registry. An unverified wallet cannot hold, receive, or transfer a Participation Token.
A Participation Token is an asset-linked entitlement to a defined economic outcome from the project's underlying asset. The specific rights conferred — including economic entitlement, redemption mechanics, governance participation, and the legal classification — are set out in each project's whitepaper.
The platform does not guarantee liquidity for any Participation Token, does not commit to an exit or redemption window outside the terms of each project's whitepaper, and does not operate a buyback obligation. Exit is supported through the secondary market and the project-specific liquidity arrangements documented at listing.
One Participation Token per project. Identity-bound at the contract level.
The platform operates a single-token architecture. Every project issues its own Participation Token under the ERC-3643 standard with the full T-REX identity stack. There is no platform-level token of any kind.
Every Participation Token implements the ERC-3643 interface. Holder eligibility is enforced through claim topics — country eligibility, identity verification tier, and lock-up status where the project requires one. Transfers, mints, and redemptions are checked against the project's compliance policy on every transaction.
Each Participation Token carries its own compliance policy on-chain — country eligibility ruleset, maximum holding cap per identity (20% for real-world asset projects), lock-up rules where applicable, and chain enablement configuration. Policy changes require a time-lock and multi-signature approval.
Every Participation Token can be enabled on more than one chain. The platform operates a lock-and-mint cross-chain bridge that preserves the identity envelope across chains. Polygon mainnet is the primary chain at launch with Ethereum mainnet as secondary for high-value projects. A Solana adapter is built and tested but disabled by default, and is activated per-project only after Certik has cleared the adapter and the bridge.
On every secondary transfer, the contract checks the receiving identity, validates holder claims, verifies the resulting balance against the holding cap, and checks the project compliance policy. Anonymous transfers are not possible. Direct wallet-to-wallet transfers between unverified counterparties are blocked at the protocol level.
Regulatory Notice: Participation Tokens are VARA-regulated Asset-Referenced Virtual Assets representing direct asset-linked entitlement to the economic performance of an identified underlying asset. Projected yields and asset valuations are indicative only, based on independent appraisals disclosed per project. No guaranteed return is offered or implied. Capital is at risk. Seek independent financial and legal advice before participating.
Digital records of participation, confirmed across three independent systems
Each Participation Token is an on-chain record linking a verified participant to a specific project. It is one of three corroborating records — not a standalone instrument. Per-project fees are disclosed in full before any subscription.
| Token Code | Project Category | Minimum Participation | Fee Schedule |
|---|---|---|---|
| L28-RE | Real estate (completed) | AED 1,000 | Disclosed per project |
| L28-OFP | Real estate (off-plan) | AED 2,500 | Disclosed per project |
| L28-GOLD | Gold and precious metals | AED 500 | Disclosed per project |
| L28-OIL | Oil and commodities | AED 5,000 | Disclosed per project |
| L28-AGRI | Agriculture and agribusiness | AED 1,000 | Disclosed per project |
| L28-ESG | ESG and carbon credits | AED 500 | Disclosed per project |
| L28-INFRA | Infrastructure development | AED 5,000 | Disclosed per project |
Token codes are project identifiers. Each project's full fee schedule is disclosed in full to the subscriber before commitment.
How your position is confirmed across three independent systems
| Record | What it contains | How to access | Governed by |
|---|---|---|---|
| Blockchain Token Record | Your Participation Token on the project's primary chain, carrying your identity claims and the project reference. | Participant portal | Block explorer | Direct contract query | Blockchain protocol (immutable) |
| Subscription Agreement | Legally binding contract confirming the participation terms and the reference code on the subscription event. | Documents section of your participant portal, always available. | UAE contract law |
| Project Holder Record | The definitive record of your position maintained under the project's governance structure. | Request certified extract through the platform. | UAE corporate law and the project structure |
Bring an Opportunity to Legacy28
Opportunities are reviewed, structured, and admitted through a governed process. Each submission undergoes documentation review, compliance screening, structuring assessment, and internal approval before marketplace admission.
Submit Opportunity for ReviewVerified project access across structured sectors
Every project is held within a dedicated SPV, approved by a four-person compliance committee, and identity-gated at the contract level.
Access Requirements
Full participation documents, subscription terms, and project-level disclosures are available to verified participants only. Complete verification to access the full marketplace.
Access Notice: Projected yields and asset valuations shown are indicative only, based on independent appraisals disclosed in full project documentation. The full VARA-compliant issuance documentation, ARVA whitepaper, reserve asset structure, SPV incorporation documents, and subscription agreements are accessible to KYC-verified participants only. No guaranteed return is offered or implied. Capital is at risk. This information does not constitute financial advice. Begin verification here.
Multi-party governance. No unilateral authority over material decisions.
Legacy28 Global is governed through four structured bodies with defined mandates, membership requirements, and approval thresholds.
| Governance Body | Mandate | Composition | Approval Threshold |
|---|---|---|---|
| Board of Directors | Ultimate oversight of corporate strategy, fee parameters, capital decisions, and emergency actions. Approves material changes to platform policy. | Chief Executive Officer, Chief Technology Officer, Non-Executive Chairman, and independent directors as appointed. | Majority standard; unanimous for constitutional changes |
| Project Approval Committee | Reviews and approves every project listing application and every material edit to a live project. Reviews the AI-assisted requirements determination, the compliance team assessment, and the supporting documentation. | Chief Executive Officer, Chief Technology Officer, Compliance Officer, and Treasury Officer. | All four members must approve; CEO override available except on AML and MLRO determinations |
| Compliance Function | Ongoing regulatory monitoring, AML/CTF programme supervision, suspicious activity review, regulatory reporting authority, and independent determinations protected from override. | Compliance Officer holding the MLRO mandate, supported by the compliance team. | Independent on every matter within the Compliance Officer and MLRO mandate |
| Technical Governance | Reviews and approves smart contract upgrades, chain enablement, identity registry changes, and security configurations. Operates the multi-signature configuration on every issuer contract. | Chief Technology Officer, Compliance Officer, and an independent technical signer appointed by the Board. | Multi-signature with documented time lock on upgrades and on high-risk compliance actions |
Over two decades of cross-sector experience spanning precision agriculture, industrial infrastructure, carbon markets, and compliance-led digital systems. Led agricultural consulting operations covering more than 450,000 hectares across North America. The platform's identity-bound token architecture and daily reconciliation framework reflect a process-first discipline informed by Lean Six Sigma methodology.
Brings strategic insight into GCC market positioning, institutional relationships, and regional governance alignment. Supports the platform's growth within the UAE and broader Gulf region through structured partnership engagement and stakeholder coordination.
Appointment pending formal confirmation. This position reflects the platform's commitment to building a complete, multi-party leadership structure with independent oversight and institutional depth.
Your position is held in place by structure, not by goodwill or assurances
Every participation position is documented in three separate systems — on-chain, contractual, and corporate — each governed by a different framework and controlled by a different party.
Where a project is structured through an SPV, the share register is maintained by a licensed corporate administrator under UAE corporate law, independent of Legacy28 Global and not directable by any single party acting alone.
Every participant receives a signed subscription agreement at position establishment — a legally binding contract under UAE law identifying the participant, the project, and the participation terms.
For SPV projects, the corporate share register is a legal document maintained under UAE corporate law. Changes require formal transfer documentation, verified identity of all parties, and applicable regulatory filings.
Material changes to a project's underlying structure require unanimous approval from the Project Approval Committee (CEO, CTO, Compliance Officer, and Treasury Officer), the independent corporate administrator, and applicable government authorities.
Your participation token on the Polygon blockchain is independently verifiable at any time. It cannot be altered without the burn-and-reissue mechanism, which requires your consent and KYC approval of the receiving party.
Every subscription is permanently linked to a unique cryptographically signed reference code generated at the moment of subscription. The reference code accompanies the on-chain identity record and the segregated escrow record held at MBank, and is written to the append-only audit log on every state-changing action.
Comprehensive daily reconciliation of all participation token records, subscription agreements, project governance records, and blockchain balances. Annual independent external audit. All reconciliation outputs anchored on-chain.
Secondary market and exit pathways, operated under the Broker-Dealer authorisation
The platform operates an internal secondary market under its VARA Broker-Dealer authorisation. The market is single venue and agency only — trades are matched by the Over the Counter Desk against a published reference price, not by an automated matching engine.
Liquidity Disclosure: The platform does not guarantee liquidity, does not commit to an exit or redemption window outside the terms of each project's whitepaper, and does not operate a buyback obligation. The platform is not a principal counterparty unless separately approved for that role. Tokens represent direct asset-linked entitlement and are not guaranteed for principal protection. Seek independent financial advice before making any participation or exit decision.
The platform operates a single-venue, agency-only secondary market. Participants submit Expressions of Interest with a limit price and a 7-day validity window (one 7-day extension permitted). The Over the Counter Desk reviews compatible Expressions of Interest and prepares match proposals against the published reference price. Both counterparties must affirm before settlement runs.
Each active project ties in one or more external liquidity providers selected at project approval. Providers onboard as verified institutional counterparties with working capital held in a segregated escrow at MBank, and participate by submitting standing Expressions of Interest on the same agency terms as other participants.
Settlement is sequenced rather than atomic — the token leg executes first via the ERC-3643 forced-transfer hook under multi-signature, and the cash leg releases only after the token leg has confirmed on chain. If the cash leg fails after the token leg has settled, an emergency unwind reverses the token leg under a three-of-four multi-signature override.
For fully negotiated transactions with a named counterparty, the platform supports bilateral peer-to-peer trades through the same Over the Counter Desk preparation, six-step pre-settlement verification, and sequenced settlement flow. An in-trade chat is available between the parties, and either party may raise a dispute before release.
Where a project's whitepaper provides for periodic or event-driven redemption, the redemption window is operated by the platform under the project terms. Redemption may be supported by the project's redemption support provider or by the underlying asset's conversion mechanism.
Regulated, compliant, and transparent from the ground up
Legacy28 Global operates as a VARA-regulated Virtual Asset Broker-Dealer and Issuer within the DMCC Free Zone. KYC is mandatory before any account activity — enforced at the contract level, not just the application layer.
| Regulatory Framework | Status |
|---|---|
| VARA (Virtual Assets Regulatory Authority, Dubai) | VARA-regulated Virtual Asset Broker-Dealer and Asset-Referenced Virtual Asset Issuer. Licenced to issue and broker digital assets representing real-world asset exposure. DMCC Free Zone, Dubai. |
| UAE Federal Decree-Law No. 4 of 2022 | Compliant with UAE federal virtual asset legislation establishing the legal basis for VARA authority over digital asset activities across the Emirate of Dubai. |
| UAE AML/CTF Legislation | Full AML/CTF programme. Appointed MLRO. Connected to UAE FIU goAML system for STR filing. |
| FATF Recommendations | Framework aligned with FATF Recommendations for VASPs, including Travel Rule (Recommendation 16). |
| DMCC Free Zone Requirements | Incorporated and licensed within DMCC. Annual compliance filings and corporate governance standards maintained. |
| Identity Verification (Third-Party Provider) | Production-tier identity verification with biometric capture, document verification, and ongoing monitoring. Sanctions and PEP screening on onboarding and on the documented periodic cadence. |
| Chain Analytics (Third-Party Provider) | Institutional-tier chain analytics. Inbound and outbound wallet screening on every transaction. Wallet risk scoring, exposure tracing, and investigative tooling for the compliance team. |
| Smart Contract Audit | Pre-launch audit on every Participation Token contract, every identity registry contract, every bridge contract, and every custom compliance hook by an institutional-grade audit firm. |
- ✓Government-issued identity document (passport, Emirates ID, or national equivalent)
- ✓Liveness check — real-time biometric verification
- ✓Proof of address dated within 3 months
- ✓Sanctions screening — OFAC, UN Security Council, EU, UAE local sanctions lists
- ✓PEP screening at onboarding and recurring basis
- ✓Adverse media screening — automated, regulatory enforcement history
- ✓Real-time AML transaction monitoring, 24 hours a day
- ✓Sanctions screening on every transaction, not just at onboarding
- ✓Daily automated reconciliation of all participant records and escrow positions
- ✓Annual independent external audit of all platform operations
- ✓Immutable on-chain audit record anchored daily
- ✓STR reporting to UAE FIU through goAML
Scope Notice: VARA regulation applies within the jurisdiction of the Dubai emirate. The platform's regulatory status does not constitute compliance certification in any other jurisdiction. Participants are solely responsible for understanding whether virtual asset participation is permitted under the laws of their own jurisdiction. The platform does not provide financial, investment, legal, or tax advice.
Not cosmetically different. Different at the level of what is technically possible.
The differences between Legacy28 Global and conventional token platforms are structural choices that change what can and cannot happen within the system itself — regardless of what any documentation says.
| Feature | Legacy28 Global | Conventional Platform |
|---|---|---|
| Token standard | ERC-3643 with the full T-REX identity stack. Every Participation Token has its own identity registry, claim topics registry, and trusted issuers registry. Identity binding is enforced by the contract. | Plain ERC-20 or similar. Identity attribution, if any, exists only at the application layer. |
| Architecture | Single-token architecture. One Participation Token per project, issued by the platform operator as the legal Issuer of record. No platform-wide deposit token. No platform recognition token. | Multi-token stacks combining utility tokens, governance tokens, and recognition tokens. Classification often ambiguous. |
| Holder identity | On every transfer, the contract checks the receiving identity through the identity registry and the holder claims through the claim topics registry. Anonymous transfers are not possible. | Tokens are transferred as-is. Compliance state of the current holder not embedded in the token. |
| Supply constraint | Tokens are minted only on confirmed settlement of a subscription order with a unique tamper-resistant reference code. Supply is structurally bounded by paid-in capital. | Token supply defined at deployment or by governance vote. No verified subscription constraint. |
| Holding cap | Maximum 20% of project supply per identity, enforced at the contract level on every transfer. Confirmed-owner carve-out per the project whitepaper. | No structural cap on holding concentration. Whale risk on every project. |
| Secondary market | Single-venue, agency-only execution under the VARA Broker-Dealer authorisation. Participants submit Expressions of Interest; the Over the Counter Desk prepares match proposals against a published reference price (VWAP → NAV → independent valuation). Sequenced settlement: token leg first, cash leg second. Bilateral peer-to-peer supported for negotiated trades. | Liquidity entirely dependent on uncoordinated secondary market demand. No defined matching priority. No agency-only protections. |
| Position verification | Three corroborating records: blockchain token balance, subscription agreement, and project holder record. Reconciled daily. | Verification typically limited to on-chain token balance alone. |
| Smart contract assurance | Independent smart contract audit before any project goes live. Multi-signature configuration on every issuer contract. Time-lock on upgrades and on high-risk compliance actions. | Audit coverage uneven. Multi-signature optional. Time-lock often absent. |
A compliance procedure is only as strong as the weakest moment someone decides not to follow it. When you embed compliance in the architecture — in the token contract itself, in the holding cap check at the contract level, in the identity check on every transfer — you stop relying on people doing the right thing and start relying on the system making the wrong thing impossible. That is the thinking behind every structural decision on this platform.
Common questions, direct answers
A Participation Token is a VARA-regulated Asset-Referenced Virtual Asset issued by the platform operator under the ERC-3643 standard for a specific project. The token represents a direct asset-linked entitlement to the economic performance of the project's underlying asset. The token holder's identity is bound to the token through the on-chain identity standard. Capital is at risk. No guaranteed return is offered or implied.
The legal classification of a Participation Token depends on the specific project and is set out in that project's whitepaper, which the participant accepts at subscription. Participation Tokens on this platform are issued under the ERC-3643 standard as identity-bound digital instruments representing a direct economic relationship with the underlying asset. Read the whitepaper for any project of interest before subscribing.
No. The platform operates a single-token architecture. There is no platform-wide deposit token, no platform-level redemption token, and no platform recognition token. Each project on the marketplace issues its own Participation Token under the ERC-3643 standard with its own contract and identity registry.
The primary secondary market is the platform's single-venue agency execution under the Broker-Dealer authorisation, where the Over the Counter Desk matches Expressions of Interest. Listing on an external venue may be supported on a project-by-project basis through a cross-venue liquidity provider, subject to the venue operating under an order-book or agency execution model and to the same identity gating so that the receiving counterparty is verified. The platform does not list Participation Tokens on automated market makers or constant-product pools. Anonymous transfer to or from an unverified address is not possible at the contract level.
Yes. Full identity verification is mandatory before any subscription, token activity, or marketplace participation. This is enforced at both the account level and the smart contract level through the on-chain identity registry. There are no anonymous participation pathways.
The platform operates a three-vendor UAE rail at launch: card-based subscriptions are processed through network.AE, crypto on-ramp and off-ramp through changer.AE, and client cash is held in segregated escrow at MBank. Bank transfers above the card threshold route to the MBank escrow account quoting the unique reference code generated at order entry. Stablecoin deposits in supported tokens are accepted on the supported chains. A Canada banking partner is available behind a feature flag for Canadian-denominated transactions. All deposits must come from accounts or wallets in your own verified name.
Every project carries its own fee schedule, disclosed in full to you before any subscription. There is no flat platform-wide fee. Fee categories may include the primary subscription fee, secondary market fees, dividend distribution fees, withdrawal fees, and early withdrawal fees. The schedule for each project is published on the project's marketplace detail page.
Yes. For real-world asset projects, no single holder may own more than twenty percent of the project supply. The cap is enforced at the contract level on every transfer. The only exceptions are the platform operator as Issuer of record and the confirmed owner of the underlying asset where documented in the whitepaper at project launch.
No. Participation Tokens are digital participation records, not ownership certificates. Legal title to the referenced asset is held within the project's governance structure, which varies by asset class. The specific rights conferred by each Participation Token are set out in that project's whitepaper, which the participant accepts at subscription.
Three independent ways: your on-chain Participation Token balance and identity claims, verifiable on the project's primary chain explorer; your subscription agreement in the documents section of the participant portal; and the project holder record maintained under the project's governance structure. All three are reconciled daily.
Access is account-based and compliance-gated. Create an account, complete identity verification, and receive approval. Once approved, log in through the participant portal using email and password with multi-factor authentication. Wallet connection happens inside the portal after your account has been verified and activated — never on the public website.
Yes. After account activation, you may optionally connect an externally controlled wallet through the participant portal. The platform supports established browser wallets and mobile wallets through the relevant connection protocol. The connection is established through a signature proof of control and the wallet passes chain analytics screening before binding to your verified identity.
Legacy28 Global FZCO operates from the DMCC Free Zone in Dubai. The entity is in the licensing process with VARA for Virtual Asset Issuer and Virtual Asset Broker-Dealer services. Current status is published on the regulator's public register. The platform does not provide financial, investment, legal, or tax advice.
Access is compliance-gated. Here is what the onboarding pathway looks like.
The verification process is structured and thorough. Wallet linking and full marketplace access open after account approval. Take your time — this is the foundation of everything that follows.
Full name, email, mobile, country of residence, and password. Your account is the compliance anchor for all subsequent activity.
Individual, Corporate, Family Office, or Institutional. Verification requirements and access thresholds vary by type.
Jurisdiction check, restricted-country screening, and eligibility acknowledgement. Participants from sanctioned jurisdictions cannot access the platform.
Identity documents, liveness check, proof of address, sanctions screening, PEP screening, and adverse media screening. Entities additionally provide incorporation documents, UBO declaration, and director verification.
Source of funds and source of wealth declaration required as part of the AML/CTF programme, particularly for participants above threshold amounts.
Confirmation that this is a utility ecosystem, that no guaranteed return is offered or implied, and that tokens do not represent equity or financial instruments.
Upon compliance approval, your account is activated. You gain access to the full marketplace, project documentation, and your participant dashboard.
Wallet linking occurs exclusively inside the approved participant portal after account activation. One approved account may link one approved wallet. This action is never available on the public website.
Account creation is free. Verification is required before any participation activity.
Ready to participate in real-world asset returns?
Begin your identity verification today. Access opens after compliance approval. All participation activity requires a verified account.