REALDEED PROPTECH (DIFC) LTD - CRYPTO TOKEN SUITABILITY POLICY

Real-World Asset (RWA) Token Generation, White-Label Agentic Integration & Blockchain Infrastructure

Pursuant to GEN Rule 3A.2.1 of the DFSA Rulebook

1. Purpose, Scope and RealDeed's Role

This Crypto Token Suitability Policy ("Policy") is established by RealDeed Proptech (DIFC) Ltd ("RealDeed" or the "Firm") pursuant to GEN Rule 3A.2.1(2)(a) of the Dubai Financial Services Authority ("DFSA") Rulebook, and in accordance with the DFSA's Supervisory Guidelines on Assessing the Suitability of Crypto Tokens.

1.1 RealDeed's Role: Technology Platform Provider

RealDeed operates as a Real Estate Tokenization Platform and white-label infrastructure layer for the tokenization of Real-World Assets ("RWA"), principally real estate. The Firm does not issue, hold, deal in, or advise on Crypto Tokens as financial instruments. Its role is to:

•     Design, deploy, and operate smart contract infrastructure on selected blockchains that enables third-party issuers, property developers, SPVs, and fund managers to generate RWA tokens representing fractional interests in real property;

•     Provide white-label tokenization services whereby clients of the Firm can mint, manage, and transfer on-chain representations of real estate assets using RealDeed's platform;

•     Maintain blockchain network connectivity and pay the native gas/network fees required to execute on-chain transactions across the assessed blockchains; and

•     Provide KYC-gated, Decentralized Identity Verification System & compliance-enabled smart contract wrappers that enforce eligibility and transfer restrictions on behalf of issuers.

Note : RealDeed does not issue, hold, sell, or manage Crypto Tokens as an investment product or financial instrument. The Firm's assessed blockchain networks (XRPL, BNB Chain, Polygon) are infrastructure layers over which clients generate, manage, and transfer RWA tokens. The assessed native tokens (XRP, BNB, MATIC/POL) are used exclusively as network fuel and smart contract execution media — not as investment assets of the Firm or its clients. This Policy applies to RealDeed's use of these tokens in connection with its technology platform activities and expressly does not cover Securities issuance, Crowdfunding, or regulated investment activities.

1.2 RWA Token Generation and White-Label Issuance

The RealDeed platform enables RWA token generation in the following principal modes:

•     Direct Issuance: Property developers or SPVs use RealDeed's platform to mint on-chain tokens representing fractional beneficial ownership interests in a specific property. RealDeed provides the smart contract framework, KYC integration, transfer restriction engine, and on-chain record management for this thing We verify the title deed with Local Land Registries to conduct the operations.

•     White-Label: Regulated institutions (fund managers, RERA-registered developers, DFSA-licensed firms) use RealDeed's platform under their own brand to issue and manage RWA tokens. RealDeed provides backend infrastructure and technology licensing; the issuing institution takes responsibility for the regulated offering.

•     Secondary Market Infrastructure: RealDeed provides the on-chain mechanism for compliant peer-to-peer transfer of RWA tokens between KYC-verified investors, including lockup enforcement and transfer approval workflows.

2. Regulatory Basis

The following instruments underpin this Policy:

•     GEN Rule 3A.2.1 – Obligation to assess suitability of Crypto Tokens before use in connection with any regulated activity;

•     GEN Rule 3A.2.1(2)(a) – Requirement to conclude on reasonable grounds, having regard to prescribed criteria, that each Crypto Token is suitable;

•     GEN Rule 3A.2.1A(c) – Documentation requirements where any negative indicator is identified;

•     GEN Rule 3A.2.1(3)(a)–(e) – The five suitability criteria: Characteristics; Regulatory Status; Market Size & Liquidity; Technology; and Compliance Compatibility;

•     DIFC Law No. 2 of 2021 (Financial Services and Markets Law, as amended);

•     DFSA AML Module – KYC/CDD and Travel Rule obligations applicable to virtual asset transfers;

•     FATF Recommendation 16 – Travel Rule requirements for virtual asset service providers.

3. Blockchains and Tokens Subject to This Assessment

RealDeed has selected three blockchain networks as the infrastructure for its RWA tokenization platform. The native tokens of these networks are assessed for suitability under GEN Rule 3A.2.1. Each token's role within the platform is set out below.

XRP

XRP Ledger (XRPL)

XRPL Native + Issued Currencies + DEX

RWA Token Issuance Layer

RWA tokens issued as XRPL Issued Currencies; RippleNet (DFSA Approved) ODL for cross-border settlement and escrow based smart contracts for staged property tokenization.

BNB

BNB Chain (BSC)

BEP-20 Smart Contracts + Binance KYC SDK

Smart Contract Execution & White-Label Token Minting

RealDeed RWA Token's minted as BEP-20 smart contracts with KYC-gated transfer restrictions; white-label client deployments on BNB Chain with custom token parameters; Binance KYC SDK integration for investor onboarding; gas fees for all on-chain interactions.

MATIC / POL

Polygon PoS / zkEVM

ERC-20 / ERC-3643 (T-REX) + ZK Proofs

Scalable RWA Token Infrastructure & zkEVM Settlement

ERC-3643 (T-REX protocol) RWA tokens with on-chain investor identity registry and compliant transfer restrictions; zkEVM deployment for preserving KYC verification; low-cost high-throughput token minting for retail investor fractions; Ethereum security inheritance for institutional-grade issuances.

4. Assessment Methodology

The Firm has assessed each Crypto Token against the five criteria under GEN Rule 3A.2.1(3)(a)–(e), interpreted in the context of RealDeed's specific role as a technology platform provider for RWA tokenization — not as a dealer, fund manager, exchange, or investment adviser. The assessment has considered:

•     The nature and scale of the Firm's DIFC operations as a technology licensor and white-label infrastructure provider;

•     The customer base — primarily regulated Property Developers, Licensed Fund Management firms.

•     The function of each assessed token as infrastructure (issuance medium, settlement rail, gas) rather than as an investment asset; and

•     All positive and negative indicators in the DFSA Supervisory Guidelines Annex, with documented justification for any negative indicators identified.

5. Individual Token Suitability Assessments

5.1 XRP – XRP Ledger (XRPL)

RWA PLATFORM ROLE – XRP / XRPL

RealDeed uses the XRP Ledger as a native RWA token issuance layer (via XRPL Issued Currencies), a cross-border settlement network (via RippleNet On-Demand Liquidity), and a decentralised exchange (DEX) and the base ODL currency. RealDeed does not hold XRP as an investment or recommend it to clients as an asset.

GEN 3A.2.1(3)(a) – Characteristics, Purpose, Governance & Founders

Rule / Criterion

Assessment Findings

Outcome

GEN 3A.2.1(3)(a)

Characteristics

Use Case & RWA Fit: The XRP Ledger was purpose-built for fast, low-cost value transfer and has native support for Issued Currencies — a built-in token issued.

RippleNet ODL for Settlement: RippleNet's On-Demand Liquidity (ODL) product uses XRP as a bridge currency for instant cross-border payment settlement. RealDeed leverages this to deliver subscription proceeds and rental distributions to NRI investors in India and the GCC without correspondent banking delays or FX friction.

Traceability: XRPL is a fully public, permissionless ledger. All issued currency balances, transfers, DEX orders, and escrow contracts are permanently recorded and inspectable via XRPL.org and compatible blockchain explorers. This enables real-time AML screening, Travel Rule compliance, and audit trail maintenance.

Governance: XRPL is governed by a decentralised validator network (Unique Node List). Protocol amendments require supermajority validator consensus over two weeks. The XRP Ledger Foundation independently supports ecosystem governance and standards development.

Founders: Ripple Labs Inc. was founded by Chris Larsen and Jed McCaleb. Key executives are publicly identified. Ripple is a U.S.-registered corporation with disclosed financials and active regulatory engagement.

Token Age: XRP launched in 2012. Over 12 years of verifiable on-chain history provides substantial data to assess long-term network resilience.

Concentration / Escrow: Ripple Labs holds the majority of total XRP supply in an on-chain escrow, releasing maximum 1 billion XRP per month via smart contract. The escrow structure is cryptographically enforced, publicly verifiable, and provides predictable supply release. RealDeed holds only minimal operational XRP for gas and ODL purposes.

✓ SUITABLE

Suitable for RWA issuance infrastructure

 GEN 3A.2.1(3)(b) – Regulatory Status

Rule / Criterion

Assessment Findings

Outcome

GEN 3A.2.1(3)(b)

Regulatory Status

UAE / DFSA: XRP is recognised as a permissible Crypto Token by the DFSA and VARA. RealDeed operates within the DFSA's framework and has confirmed XRP's permissibility with reference to applicable DFSA publications.

Global Recognition: XRP is formally recognised or classified in Japan (FSA – permitted crypto asset since 2017), Singapore (MAS – Digital Payment Token under Payment Services Act), EU (recognised on MiCA-regulated exchanges), and the UK (FCA – registered exchange listings). These classifications support a finding of broad regulatory acceptance.

Issuer Supervision: Ripple Labs Inc. holds a U.S. FinCEN Money Services Business registration and a New York BitLicense. Ripple is subject to ongoing AML/CFT compliance obligations and regulatory engagement in the UAE, Singapore, and UK.

SEC Litigation (Historical Negative Indicator): The U.S. SEC brought action against Ripple in 2020 alleging XRP constituted a security. In July 2023, the U.S. District Court ruled that XRP sold on secondary markets to retail investors does not constitute a security. The matter was subsequently settled in 2024 with no ongoing injunction. The Firm treats this as a resolved historical matter. No DFSA, VARA, or UAE enforcement action has been taken. XRP continues to trade on regulated exchanges globally without restriction.

Conclusion on Enforcement: Given the litigation's resolution, the absence of UAE regulatory action, and RealDeed's non-investment, infrastructure-only use of XRPL, the Firm concludes this historical matter does not prevent suitability.

✓ SUITABLE

Suitable – historical litigation resolved

GEN 3A.2.1(3)(c) – Market Size, Liquidity & Trading History

Rule / Criterion

Assessment Findings

Outcome

GEN 3A.2.1(3)(c)

Market & Liquidity

Market Capitalisation: XRP consistently ranks top-10 globally by market cap (typically USD 30–60 billion), reflecting broad ecosystem adoption and liquidity sufficient for RealDeed's operational needs.

Liquidity: Listed on virtually all major regulated exchanges with daily trading volumes in the billions of USD. The Firm requires only minimal XRP holdings for gas and ODL operations, well within available market depth.

Price Transparency: XRP prices are observable in real-time via Bloomberg, Refinitiv, CoinGecko, and CoinMarketCap. The Firm can accurately price XRP at all times.

Supply Transparency: Total supply 100 billion XRP; circulating supply ~55 billion. Remainder in on-chain escrow. Supply metrics are consistent across all major data sources and on-chain records.

Volatility Note: For ODL settlement use, XRP price exposure is minimised through near-instantaneous conversion. RealDeed does not hold XRP as a reserve asset. For RWA token issuance via XRPL Issued Currencies, XRP is used as a trust line medium only; the RWA token's value is denominated in fiat or property value.

✓ SUITABLE

Suitable

GEN 3A.2.1(3)(d) – Technology

Rule / Criterion

Assessment Findings

Outcome

GEN 3A.2.1(3)(d)

Technology

Network Maturity: XRPL operational since 2012 — over 12 years of continuous operation with billions of transactions processed. No material protocol-level security incidents. Demonstrated resilience across multiple market cycles.

RWA-Native Features: XRPL provides native Issued Currencies (token issuance without smart contracts), on-chain DEX, Escrow (time/condition-locked payments), and Payment Channels — all relevant to RealDeed's RWA platform. The upcoming XRPL EVM Sidechain extends compatibility with Solidity-based smart contracts.

Consensus: Federated Byzantine Agreement (FBA) via Unique Node List. Provides 3–5 second finality with negligible energy consumption. No mining, no PoW attack vectors.

Node Distribution: Hundreds of validator nodes operated by universities, financial institutions, and exchanges globally. Geographic diversity reduces single-point failure risk.

Incident Response: Formal amendment process requires supermajority validator consensus. Historical protocol upgrades delivered without disruption. XRP Ledger Foundation maintains developer documentation, bug bounty programs, and security advisories.

Smart Contract Compatibility for RWA: XRPL Hooks (upcoming) and the EVM Sidechain enable programmable compliance logic, further strengthening XRPL's suitability as an RWA issuance layer.

✓ SUITABLE

Suitable – RWA-native capabilities

GEN 3A.2.1(3)(e) – DFSA Compliance Compatibility

Rule / Criterion

Assessment Findings

Outcome

GEN 3A.2.1(3)(e)

Compliance Compatibility

AML Screening: XRPL's fully public ledger enables real-time wallet risk scoring and transaction monitoring via Chainalysis, Elliptic, and TRM Labs. RealDeed integrates on-chain AML screening into DIDIT KYC Gateway.

Travel Rule: XRPL supports structured memo fields for originator and beneficiary data transmission. Ripple has commercially deployed Travel Rule protocol integrations (via Notabene) on XRPL. RealDeed will implement Travel Rule compliance for all XRPL transfers above applicable thresholds.

Sanctions Screening: All XRPL wallet addresses will be screened against OFAC, UN, UAE, and EU sanctions lists before any transaction is processed.

DFSA Rules Compatibility: No aspect of XRP or XRPL technology prevents the Firm from complying with applicable DFSA-administered Laws and Rules. The platform's use of XRPL is fully transparent, auditable, and compatible with the Firm's AML/CFT obligations.

✓ SUITABLE

Suitable

5.2 BNB – BNB Chain (Binance Smart Chain)

RWA PLATFORM ROLE – BNB / BNB CHAIN

RealDeed deploys ERC-20-equivalent BEP-20 smart contracts on BNB Chain for PropPass RWA token minting. BNB Chain's EVM compatibility enables deployment of ERC-3643 (T-REX) compliant transfer restriction contracts for regulated RWA issuance. BNB is used exclusively as gas for smart contract execution. RealDeed does not use Binance's centralised exchange and maintains independent custody of all operational BNB holdings.

GEN 3A.2.1(3)(a) – Characteristics, Purpose, Governance & Founders

Rule / Criterion

Assessment Findings

Outcome

GEN 3A.2.1(3)(a)

Characteristics

Use Case & RWA Fit: BNB Chain is an EVM-compatible blockchain with high throughput and low transaction costs, making it well-suited for frequent smart contract interactions involved in RWA token minting, investor onboarding, and compliance enforcement. BEP-20 tokens are the standard for RWA issuance on BNB Chain.

ERC-3643 / T-REX on BNB Chain: RealDeed deploys the ERC-3643 (T-REX) standard for RWA tokens on BNB Chain. T-REX provides on-chain investor identity registry (ONCHAINID), transfer restriction enforcement, and regulatory compliance logic. This standard was specifically designed for compliant security and RWA token issuance.

White-Label Deployments: BNB Chain's developer ecosystem and low deployment costs make it the preferred chain for RealDeed's white-label clients who require rapid, cost-effective RWA token infrastructure.

Traceability: BNB Chain is a fully public EVM-compatible blockchain. All transactions are visible via BscScan. AML screening is fully supported by Chainalysis, TRM Labs, and Elliptic.

Governance: BNB Chain uses Proof-of-Staked-Authority (PoSA) with 21 elected validators. The BNB Chain Committee oversees protocol governance. Documentation is published at docs.bnbchain.org.

NEGATIVE INDICATOR – Founder: Changpeng Zhao (CZ), Binance founder and BNB Chain primary developer, pleaded guilty to U.S. federal AML charges in November 2023. This is a negative indicator under GEN 3A.2.1(3)(a). However: BNB Chain is a decentralised open-source protocol operationally independent of CZ's personal legal status. The Firm's RWA token infrastructure does not require CZ or Binance's ongoing involvement. The protocol's codebase, validator set, and governance mechanisms continue to function absent any individual's participation. On this basis the indicator does not prevent suitability for RealDeed's specific technology platform use case.

Token Age: BNB launched 2017 (Binance ICO); migrated to BNB Chain mainnet 2020. Over 7 years of operating history.

✓ SUITABLE

Suitable – with conditions (see Annex A)

GEN 3A.2.1(3)(b) – Regulatory Status

Rule / Criterion

Assessment Findings

Outcome

GEN 3A.2.1(3)(b)

Regulatory Status

UAE Recognition: VARA has approved BNB for trading by licensed VASPs in the Emirate of Dubai. The DFSA has not issued any prohibition on BNB or BNB Chain usage.

Global Listings: BNB is listed on regulated exchanges in the EU (MiCA-compliant), Japan (FSA-registered), and Singapore (MAS Payment Services Act-licensed). These listings indicate jurisdictional regulatory acceptance.

NEGATIVE INDICATOR – Enforcement: In November 2023, Binance and its affiliates agreed to a USD 4.3 billion settlement with the U.S. DOJ, FinCEN, and CFTC arising from AML and sanctions compliance failures. This represents a significant negative indicator under GEN 3A.2.1(3)(b) which requires documented justification.

Justification for Suitability Despite Enforcement: (i) The enforcement action targeted Binance's centralised exchange — not BNB Chain as a decentralised protocol. (ii) The settlement includes a monitored compliance programme with independent compliance monitors, providing ongoing regulatory accountability. (iii) Binance retains active VASP licenses in multiple jurisdictions subject to enhanced supervision. (iv) RealDeed does not custody assets with Binance, does not route PropPass transactions through Binance's exchange, and holds only minimal operational BNB for gas fees in independently managed wallets. (v) Enhanced Due Diligence (EDD) is applied to all BNB-related transactions as a compensating control.

Conclusion: The Firm concludes BNB Chain remains suitable for its specific RWA token infrastructure use case given the structural separation between Binance's exchange and the BNB Chain protocol, and the compensating controls applied.

✓ SUITABLE

Suitable – with EDD & documented justification

GEN 3A.2.1(3)(c) – Market Size, Liquidity & Trading History

Rule / Criterion

Assessment Findings

Outcome

GEN 3A.2.1(3)(c)

Market & Liquidity

Market Capitalisation: BNB ranks consistently top-5 globally by market cap (typically USD 70–90 billion). This reflects substantial ecosystem adoption and provides confidence in network continuity.

Liquidity: BNB is listed on all major regulated exchanges with daily volumes in the billions of USD. The Firm's gas fee requirements represent a negligible fraction of available liquidity.

Price Transparency: Real-time BNB prices are observable across all major data providers. The Firm can accurately price BNB at all times.

Supply: Deflationary supply model with quarterly on-chain burns. Current circulating supply and burn records are fully verifiable on-chain and consistent across data sources.

RWA Gas Cost Efficiency: BNB Chain's low gas costs (typically USD 0.01–0.20 per smart contract interaction) make it the most cost-effective chain for high-frequency PropPass RWA token operations.

✓ SUITABLE

Suitable

GEN 3A.2.1(3)(d) – Technology

Rule / Criterion

Assessment Findings

Outcome

GEN 3A.2.1(3)(d)

Technology

Network Maturity: BNB Chain operational since September 2020 — approximately 5 years. Consistently among the highest-throughput EVM chains by transaction count.

EVM Compatibility for RWA Smart Contracts: Full EVM compatibility enables deployment of audited RWA token standards including ERC-3643 (T-REX), ERC-1400 (Security Tokens), and custom compliance-wrapped ERC-20 contracts. RealDeed's white-label smart contract library is directly deployable on BNB Chain.

Consensus: PoSA with 21 validators. Block time approximately 3 seconds. Low finality time is optimal for PropPass transaction throughput.

NEGATIVE INDICATOR – Security Incident: In October 2022, the BSC Token Hub cross-chain bridge was exploited, allowing approximately USD 570 million in BNB to be minted unauthorisedly. Validators halted the network within approximately 8 hours and a subsequent hard fork patched the vulnerability. The Firm notes this as a negative indicator but concludes: (i) PropPass does not use cross-chain bridge infrastructure on BNB Chain; (ii) the network demonstrated effective incident response and coordinated remediation; (iii) no subsequent protocol-level exploit has occurred.

Upgradability: BNB Chain has delivered multiple hard fork upgrades since launch. An active roadmap (BNB Chain Evolution Proposal process) ensures ongoing security and performance improvement.

Smart Contract Audit Standards: RealDeed's BNB Chain RWA token contracts will be subject to third-party security audits (OpenZeppelin or equivalent) prior to deployment.

✓ SUITABLE

Suitable – bridge risk noted; proppass excludes bridge use

GEN 3A.2.1(3)(e) – DFSA Compliance Compatibility

Rule / Criterion

Assessment Findings

Outcome

GEN 3A.2.1(3)(e)

Compliance Compatibility

AML Screening: Full BNB Chain coverage from Chainalysis, TRM Labs, and Elliptic. All wallet addresses and transaction flows are screened prior to PropPass onboarding.

Travel Rule: BNB Chain supports Travel Rule compliance through standard VASP data-sharing protocols. RealDeed integrates Travel Rule tooling for all above-threshold transfers.

ERC-3643 / T-REX Compliance Engine: The T-REX standard's ONCHAINID module enforces investor identity and eligibility at the smart contract level, preventing transfer to non-whitelisted addresses. This provides a DFSA-compatible compliance layer embedded in the RWA token contract itself.

Enhanced Due Diligence: Given BNB Chain's enforcement history, RealDeed applies EDD to all BNB-related transactions, maintains documented gas wallet records, and does not use Binance's centralised infrastructure for PropPass operations.

DFSA Rules: No aspect of BNB or BNB Chain technology prevents the Firm from complying with applicable DFSA-administered Laws and Rules. The independent custody arrangement and EDD framework provide adequate compensating controls.

✓ SUITABLE

Suitable with EDD

5.3 MATIC / POL – Polygon PoS / Polygon zkEVM

RWA PLATFORM ROLE – POL / POLYGON

RealDeed deploys ERC-3643 (T-REX) compliant RWA tokens on Polygon PoS for retail-accessible, low-cost fractional property token issuance. For institutional-grade issuances requiring enhanced privacy and Ethereum-level security, RealDeed uses Polygon zkEVM, which enables zero-knowledge proof verification of KYC credentials without exposing investor identity on-chain. POL (previously MATIC) is used exclusively as gas for smart contract execution. Polygon's EVM compatibility and Ethereum security inheritance make it the preferred chain for scalable PropPass deployments.

GEN 3A.2.1(3)(a) – Characteristics, Purpose, Governance & Founders

Rule / Criterion

Assessment Findings

Outcome

GEN 3A.2.1(3)(a)

Characteristics

zkEVM for Privacy-Preserving KYC: Polygon zkEVM enables zero-knowledge proofs for investor KYC verification — the smart contract can verify that an investor is KYC-compliant without revealing their identity on-chain. This is particularly relevant for high-net-worth and institutional PropPass clients requiring data privacy.

Governance: Polygon is governed by the Polygon Protocol Council and PolygonDAO. Protocol upgrades are community-governed. The MATIC-to-POL migration (September 2024) was executed via on-chain governance and is fully documented.

Founders: Polygon was founded by Jaynti Kanani, Sandeep Nailwal, Anurag Arjun, and Mihailo Bjelic — all publicly identified. No adverse regulatory or legal findings against founders.

Token Age & Migration: MATIC launched via Binance Launchpad IEO in 2019. POL (successor token) launched September 2024 as part of Polygon 2.0. Combined network history exceeds 6 years. The migration is on-chain and non-disruptive.

✓ SUITABLE

Suitable – strong RWA smart contract ecosystem

GEN 3A.2.1(3)(b) – Regulatory Status

Rule / Criterion

Assessment Findings

Outcome

GEN 3A.2.1(3)(b)

Regulatory Status

UAE Recognition: VARA has approved MATIC/POL for trading by licensed VASPs. No DFSA restriction or enforcement action applies to MATIC/POL.

EU / MiCA: MATIC/POL is listed on MiCA-compliant regulated exchanges in the EU. Multiple MiCA-licensed operators classify MATIC/POL as a utility token.

NEGATIVE INDICATOR – SEC References: In June 2023, the U.S. SEC referenced MATIC in enforcement complaints against Coinbase and Binance, characterising it as a potential security in those specific secondary-market trading contexts. No enforcement action was brought against Polygon Labs or the Polygon Foundation.

Justification for Suitability: (i) No SEC action was taken against Polygon Labs or the Foundation; (ii) MATIC/POL continues to trade on VARA-approved and MiCA-regulated exchanges without restriction; (iii) RealDeed uses POL exclusively as a gas token for smart contract execution, not as an investment instrument offered to clients; (iv) the characterisation related to exchange trading activity, not to technology platform use of a gas token; (v) multiple other regulators (MAS, JFSA) have not adopted the SEC's characterisation.

Issuer: Polygon Foundation (Cayman Islands); Polygon Labs (USA). Both entities operate transparently with public governance disclosures.

✓ SUITABLE

Suitable – with documented SEC note

GEN 3A.2.1(3)(c) – Market Size, Liquidity & Trading History

Rule / Criterion

Assessment Findings

Outcome

GEN 3A.2.1(3)(c)

Market & Liquidity

Market Capitalisation: MATIC/POL typically ranks within the top 20–30 globally by market cap (USD 5–10 billion range), reflecting substantial ecosystem depth.

Liquidity: Listed on all major regulated exchanges. Daily trading volumes comfortably exceed the Firm's minimal gas fee operational requirements.

Price Transparency: Observable in real-time across all major data providers. The Firm can Accurately price POL/MATIC at all times.

Supply Disclosure: POL total supply 10 billion with inflationary staking rewards (3.0% annually, split between validators and community treasury). Supply mechanics are fully disclosed in Polygon 2.0 documentation and verifiable on-chain.

Cost Efficiency for RWA: Polygon PoS transaction costs (typically USD 0.001–0.05 per interaction) are among the lowest of all EVM-compatible chains, making it optimal for retail investor PropPass Token operations where cost efficiency directly affects investor returns.

✓ SUITABLE

Suitable

GEN 3A.2.1(3)(d) – Technology

Rule / Criterion

Assessment Findings

Outcome

GEN 3A.2.1(3)(d)

Technology

Network Maturity: Polygon PoS operational since 2020 (approximately 5 years). Polygon zkEVM launched March 2023. Combined processing of billions of transactions with consistent uptime.

Ethereum Security Inheritance (zkEVM): Polygon zkEVM posts ZK proofs to Ethereum mainnet, meaning zkEVM transactions inherit Ethereum's security guarantees. For institutional RWA issuances on PropPass, this provides a level of cryptographic assurance beyond standard EVM chains.

ERC-3643 / T-REX Native Environment: Polygon is the reference deployment environment for the ERC-3643 T-REX standard. Tokeny (the T-REX developer) has deployed production RWA token infrastructure on Polygon for institutional issuers globally. RealDeed benefits from an established audited contract ecosystem.

Consensus: Polygon PoS uses delegated Proof-of-Stake with 100+ validators. Block time approximately 2 seconds. Polygon zkEVM inherits Ethereum validator security via ZK proof verification on L1.

Security: No material PoS mainnet exploits. Bridge-level vulnerabilities addressed through ongoing audits and bug bounty programs. Polygon Labs maintains formal security audit partnerships with Trail of Bits and OpenZeppelin.

Polygon 2.0 Roadmap: The Polygon 2.0 architecture (AggLayer, zkEVM, POL staking) positions Polygon as a multi-chain ZK interoperability hub. This roadmap strengthens long-term suitability for enterprise RWA infrastructure.

✓ SUITABLE

Suitable – premium RWA infrastructure chain

GEN 3A.2.1(3)(e) – DFSA Compliance Compatibility

Rule / Criterion

Assessment Findings

Outcome

GEN 3A.2.1(3)(e)

Compliance Compatibility

AML Screening: Polygon's public ledger enables full AML screening via Chainalysis, TRM Labs, and Elliptic. RealDeed integrates on-chain screening for all PropPass wallet addresses.

Travel Rule: Polygon supports Travel Rule compliance through standard VASP data-sharing protocols and commercial Travel Rule solutions.

ZK KYC for Privacy-Preserving Compliance: Polygon zkEVM enables the deployment of ZK-proof-based KYC verification, allowing the smart contract to confirm an investor is compliant without exposing identity data on-chain. This is directly compatible with DFSA data protection obligations and supports GDPR-equivalent privacy standards.

ERC-3643 Compliance Engine: The ONCHAINID and T-REX transfer restriction system embedded in RealDeed's Polygon-deployed RWA token contracts enforces compliance at the protocol level — preventing any non-whitelisted address from receiving PropPass Tokens.

DFSA Rules: No aspect of POL/MATIC or Polygon technology prevents the Firm from complying with applicable DFSA-administered Laws and Rules.

✓ SUITABLE

Suitable – ZK-enabled compliance infrastructure

6. Summary Suitability Matrix

The table below summarises assessment outcomes across all five GEN Rule 3A.2.1 criteria for each assessed Crypto Token. Overall suitability is found where all five criteria pass, with documented justification for any negative indicators identified.

Token / Chain

(a) Characteristics

(b) Regulatory

(c) Market

(d) Technology

(e) Compliance

Overall

Key Conditions / Notes

XRP

XRP Ledger

✓

✓

✓

✓

✓

SUITABLE

BNB

BNB Chain

✓

✓

✓

✓

✓

SUITABLE

POL/MATIC

Polygon PoS / zkEVM

✓

✓

✓

✓

✓

SUITABLE

XRP – Conditions

Monitor Ripple escrow releases quarterly; maintain XRPL Travel Rule memo compliance; apply AML screening to all XRPL trust lines and DEX orders on PropPass; review SEC settlement status annually.

BNB – Conditions

No Binance exchange custody; apply EDD to all BNB transactions; exclude BSC cross-chain bridge use; audit BNB Chain smart contracts before deployment; monitor DOJ monitored settlement status semi-annually; independent BNB gas wallet required.

POL – Conditions

Monitor SEC enforcement landscape quarterly; confirm VARA-approved exchange listings remain current; track Polygon 2.0 AggLayer deployment for any architectural changes affecting PropPass contract compatibility; maintain ERC-3643 contract audit currency.

7. Ongoing Monitoring and Review Framework

Suitability is not a static determination. RealDeed maintains a structured monitoring programme to ensure continued suitability of each assessed blockchain and its native token.

7.1 Trigger-Based Reassessment Events

An immediate reassessment shall be initiated upon any of the following:

•     New DFSA enforcement action, guidance, or public statement regarding any assessed token or blockchain;

•     New enforcement action or ban in a jurisdiction material to RealDeed's operations;

•     Material change in governance, consensus mechanism, token economics, or founding team;

•     FATF grey-listing of a material jurisdiction; and

•     Material change in RealDeed's licensed activities or operational scope within the DIFC.

7.2 Periodic Review Schedule

Review Type

Frequency

Scope

Market & Liquidity Monitor

Monthly

Market cap, trading volume, exchange listings, and token concentration metrics for XRP, BNB, and POL.

Technology & Smart Contract Review

Quarterly

Protocol upgrade monitoring, security audits, incident reports, and node health for XRPL, BNB Chain, and Polygon. Review of ERC-3643 contract audit currency.

Enforcement Tracker

Semi-annual

Status of DOJ monitored settlement for Binance; Ripple/SEC settlement compliance; any new enforcement relating to assessed tokens.

Full Policy Reassessment

Annual

Complete reassessment against all GEN 3A.2.1 criteria with updated evidence base. Board approval required to maintain suitability finding

Recordkeeping

All suitability assessment records, supporting evidence, monitoring reports, and review outcomes shall be retained for a minimum of six (6) years, consistent with DFSA Rulebook (GEN) requirements and the Firm's Records Retention Policy.

9. Declarations and Sign-Off

The undersigned confirm that this Policy has been prepared with due care and on reasonable grounds, supported by objective evidence, pursuant to GEN Rule 3A.2.1 of the DFSA Rulebook and the DFSA's Supervisory Guidelines on Assessing the Suitability of Crypto Tokens.

Annex A – Negative Indicator Register

Pursuant to GEN Rule 3A.2.1A(c), the following register documents all negative indicators identified during the assessment and the Firm's documented justification for why the relevant token remains suitable for RealDeed's specific technology platform use case notwithstanding such indicator.

Note: RealDeed Proptech (DIFC) Ltd is not a financial services company, crowdfunding platform, or tokenization platform in any jurisdiction, and is not regulated by VARA, DFSA, or SCA. As a DIFC-incorporated entity, the Company voluntarily adheres to DFSA standards and best practices on a good-faith basis.

Assessment Scope Note :. Because RealDeed is a technology platform provider, the relevant question for each criterion is not whether the token is suitable as an investment product for retail clients, but whether the token's blockchain infrastructure is technically sound, traceable, regulatory-compatible, and adequate as a medium for RWA token generation and white-label issuance. Suitability findings are specific to this technology platform use case and do not constitute an endorsement of any assessed token as an investment.