How do VCs evaluate RWA projects? A set of due diligence logic from a crypto fund.

CN
6 hours ago

Author: Terrence Qiu

I. Five Core Questions VCs Will Ask (Due Diligence Checklist)

Are the assets real? Is there a verifiable list/certificate from a third party (bond numbers, custody gold bar certificates, accounts receivable contracts, carbon credit certification documents, etc.); has independent auditing and on-chain disclosure been introduced? Can compliance be achieved? In which jurisdiction are the issuance/custody/exchanges located? Have the necessary licenses or SRO identities been established (such as RIA, trust, EU MiCA, Swiss VQF, etc.)? Are transfer restrictions and KYC/AML included in the contract process? Is the scale and revenue sustainable? Current AUM/TVL, multi-channel distribution capabilities, sources of liquidity, gross/net interest margin structure, and replicable expansion paths. Is risk control engineered? Beyond custody and auditing, are there on-chain white/blacklists, lock-up/freezing mechanisms, automated reconciliation and alerts, oracles, and data feedback? Is the team and capital endorsement aligned? Do core members "understand finance + understand compliance + understand on-chain"; are there first-tier institutions/strategic investors backing them (not just providing money, but also resources/channels/customers)?

II. Summary of Two Recent Cases

Case A: Huma Finance (PayFi: A dedicated network for payment × financing of RWA)

1) Team and Background

Co-founder Richard Liu: Former head of engineering at Google (led the development of Google Fi and other 0→1 products), the startup Leap.ai was acquired by Facebook in 2019; later served as EarnIn CTO (a leading salary advance fintech in the U.S.)—clearly has a dual background in technology and finance.

Co-founder Erbil Karaman: Former head of growth at Facebook, head of consumer products at Lyft, later served as EarnIn Chief Product Officer (CPO), focused on growth and financial user products.

Investors include Distributed Global, Hashkey Capital, Folius Ventures, Stellar Development Foundation, TIBAS Ventures. In 2024, acquired the largest client Arf: Arf is a cross-border clearing and revolving credit platform, a member of the Swiss VQF self-regulatory organization (AML/CFT compliance), with long-term cooperation and case disclosures with Circle, Solana, and Scroll+.

2) Project Highlights

Announced $38 million funding in September 2024: Approximately $10 million in equity; approximately $28 million entering the platform in the form of "revenue-generating RWA assets" (a mixed structure of "funds + asset allocation on the platform"), of which Stellar Development Foundation (SDF) provides $10 million; and for a period, the tokenized assets on Scroll are only open to qualified investors. → This type of "partially asset-based entry" structure typically reflects the investor's bet on the asset-side revenue curve, rather than just equity valuation.

3) Summary of Operations and Risk Control Measures

Public statement after merger: Cumulatively processed over $1.8 billion in payment financing transactions; positioned to "financialize the time value of payments," emphasizing the creation of a low-risk, short-duration asset pool from real payment receivables/settlements.

Arf operates under the supervision of VQF in Switzerland (anti-money laundering self-regulatory organization), with mature case examples of compliance clearing paths with USDC; this compliance foundation provides Huma with the prerequisites for "cross-border amplification."

4) Summary of Compliance Pathways

Through a combination of Swiss SRO (VQF) + U.S./Asian payment network partners, prioritizing the penetration of "cross-border payment revolving credit" as a type of ETF-like underlying asset (short-term, recyclable, with historically very low default rates for B2B receivables/settlements).

Deep cooperation with Solana/Stellar, combined with the qualified investor threshold on Scroll (EVM ZK), forming a dual-track system of "public chain payment performance + EVM side qualified investor asset issuance."

5) Research and Investment Perspective

Advantages: Strong financial/payment product background of the team; Arf's VQF and USDC operational cases provide strong compliance and settlement credibility; the "funds + asset allocation" mixed entry indicates investors' preference for real sources of revenue (rather than just betting on tokens).

Concerns:

  1. Will the expansion on the asset side increase credit and regional risks (consistency in KYC/AML across multiple jurisdictions, sanctions list screening)?

  2. The liquidity constraints of the "qualified investor" window (limited secondary transfers) and whether it will reach larger investors in the future.

Case B: Plume Network (Crypto-native chain + back-end for RWA)

1) Team and Background

Co-founded by Chris Yin, Teddy Pornprinya, Eugene Shen (2023/2024), headquartered in NYC; team members come from Coinbase, dYdX, JP Morgan, Robinhood Crypto, etc. In May 2025, co-founder Eugene Shen unfortunately passed away (the company issued an obituary and external statement).

Funding: $10 million seed round in May 2024 (led by Haun Ventures, Galaxy, etc.); $7 million strategic investment from Apollo Global Management in April 2025 (exact amount undisclosed); and announced total funding of approximately $30 million in collaboration with several traditional/crypto institutions.

The launched mainnet already includes over 50 dApps, covering various fields, from tokenized gold, private equity, durian farms, mining rights to ride-hailing services, etc.

2) Project Highlights

Apollo's entry as a strategic ticket ("seven-figure"): conventionally focuses more on resource synergy and asset management ecosystem integration rather than short-term financial returns; at the same time, Plume announced a $25 million ecosystem fund in January 2025, aimed at a platform approach of "bringing investment into the chain + project support."

3) Summary of Operations and Risk Control Measures

Public statement after mainnet launch in June 2025: RWA TVL/AUM exceeds $200 million, with over 400,000 addresses that have completed over 55 million transactions on the mainnet, and an average daily transaction volume of about 6 million. Ecosystem integration with Curve, Morpho and various RWA issuers (including some traditional asset management brands).

Productizing the compliance module: By using on-chain components for whitelisting, transfer limits, information disclosure, and KYC/AML processes, it aims to reduce integration costs for issuers and institutions, intending to become the "compliance module/settlement layer for RWA."

4) Summary of Compliance Pathways

Maintains policy communication with U.S. financial regulatory authorities, Hong Kong Monetary Authority, etc.; differentiates itself with a "crypto-native experience" rather than a purely licensed closed environment.

5) Research and Investment Perspective

Advantages:

  1. The "chain + back-end + ecosystem fund" trio is beneficial for forming network effects in the early stages;

  2. Apollo's entry is a strong signal (penetration of asset management resources and institutional clients).

Concerns:

  1. The TVL and "number of holders" metrics come from a combination of project and third-party statistics, requiring thorough verification (details from DeFiLlama, RWA.xyz);

  2. The "toolization" of compliance needs multi-version adaptation for jurisdictions and asset types, which may lead to increased product complexity and customization costs in the short term.

III. Financing Trends in the Sector

First three quarters of 2024: According to PANews/BlockWeeks, 26 RWA projects raised nearly $250 million; primarily in seed/strategic rounds, with most amounts in the million-dollar range, showing a significant increase in enthusiasm since the second quarter.

Structurally, government bonds/bonds, infrastructure (chain and compliance modules), PayFi received more concentrated funding; gold/real estate steadily expanded; carbon assets experienced significant fluctuations in financing due to policy and certification criteria. Interpretation: Capital is shifting from single-point experiments to combinations that are "scalable + clear compliance paths + institutional collaboration," with strategic investments (like Apollo → Plume) and "equity + asset allocation" mixed structures (like Huma) becoming common forms in 2024-2025.

Conclusion

RWA is no longer a "storytelling" sector, but a hard collision of financial compliance and on-chain innovation.

From the VC perspective, the due diligence logic is very clear:

  • First ask about assets—no real, auditable assets, no discussion;

  • Then look at compliance—without licenses and clear regulatory paths, it's hard to secure large investments;

  • Next is the team and model—only those who understand finance, compliance, and on-chain can be backed;

  • Finally, the narrative—the story is just a seasoning, not the key factor in deciding whether to invest.

Recent cases of Huma and Plume showcase the complexity of successful projects, which must cover all aspects. For detailed project specifics, refer to the materials below for a more in-depth interpretation. This article aims to provide a lightweight information summary, allowing everyone to feel the evolution of compliance projects on-chain today.

Reference Materials

  • CoinDesk: Tokenized RWA Platform Huma Finance Gets $38M Investment

  • Huma Finance Official Announcement: Huma × Arf Merger

  • Arf Official Website: VQF Compliance

  • Crunchbase: Richard Liu

  • LinkedIn: Erbil Karaman

  • The Block: Plume Network Raises $10M to Bring RWA On-Chain

  • Binance News: Apollo Invests in RWA Platform Plume

  • Decrypt: Apollo Invests in Plume RWA

  • Plume Network Official Website: Mainnet Launch Announcement

  • BlockWeeks: 2024 Q3 RWA Financing Report

Disclaimer

This report is solely an analysis of blockchain and fintech trends and does not constitute any investment advice. Readers should make cautious decisions based on their own circumstances and bear the corresponding risks.

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