roowang

Shariah-Compliant Real Estate Investment

Roowang – Comprehensive Operational Flow &
Stakeholder Documentation

Prepared for Securities Commission aFINity Team Consultation
Date: May 28, 2025

Executive Summary

Roowang offers a Shariah-compliant platform for fractionalized real estate investment, digitizing property assets into secure, transparent tokens. This comprehensive documentation outlines our end-to-end operational process, stakeholder ecosystem, and regulatory compliance framework to demonstrate investor protection, operational transparency, and clear accountability throughout the asset lifecycle.

1. Detailed End-to-End Operational Process

Phase 1: Asset Origination & Structuring

Step 1: Asset Origination & Screening

Responsible Party: Acquisitions Team
Process: Property owners initiate discussions; initial screening for location, yield potential, and market conditions
Outcome: Preliminary asset assessment and go/no-go decision

Step 2: Desktop Valuation

Responsible Party: Valuation Analyst → Chartered Valuer
Process: Independent property valuation using comparable sales, income approach, and market analysis
Dependency: Step 1 data package
Quality Control: Professional valuation standards and certification

Step 3: Letter of Intent (LOI) Negotiation

Responsible Party: Acquisitions Lead & Legal Counsel
Process: Price negotiation based on valuation; legal terms establishment
Contingency: Renegotiate if valuation variance exceeds 10%
Outcome: Signed preliminary agreement

Phase 2: Legal Structuring & Compliance

Step 4: SPV/Trust Formation (Shariah-Aligned)

Responsible Party: Corporate Legal & Shariah Adviser
Process: Establish Special Purpose Vehicle or Trust structure ensuring Shariah compliance
Key Requirements: No riba (interest), gharar (excessive uncertainty), or prohibited activities
Dependency: Signed LOI from Step 3

Step 5: Comprehensive Due Diligence

Responsible Party: External DD Firm & Compliance Officer
Process: Legal title verification, structural surveys, environmental checks, zoning compliance
Quality Gate: Major issues trigger return to Step 3 for renegotiation
Documentation: Complete due diligence report for regulatory submission

Phase 3: Technology Implementation & Governance

Step 6: Token & Smart Contract Design

Responsible Party: Blockchain Developers & Tech Compliance
Process: Design fractional ownership tokens and automated smart contracts
Key Features: Rent distribution automation, ownership tracking, compliance enforcement
Input: Legal structure from Step 4

Step 7: Regulatory Sandbox Submission

Responsible Party: Regulatory Affairs Manager
Process: Submit comprehensive application to Securities Commission
Requirements: Complete design package, compliance documentation
Outcome: Regulatory approval to proceed

Step 8: Security Audit & Deployment

Responsible Party: Independent Security Auditor & DevOps Team
Process: Third-party smart contract security audit and blockchain deployment
Quality Assurance: Independent verification of contract security and functionality
Dependency: Sandbox approval from Step 7

Phase 4: Investor Onboarding & Primary Sale

Step 9: Investor Onboarding (e-KYC)

Responsible Party: KYC Vendor → Compliance Engine
Process: Digital identity verification, AML screening, accredited investor verification
Technology: Automated compliance engine for real-time monitoring
Dependency: Live smart contracts from Step 8

Step 10: Primary Token Sale

Responsible Party: Finance Operations & Payment Gateway
Process: Token offering to qualified investors with escrow protection
Safeguards: Soft-cap mechanism with automatic refunds if funding threshold not met
Outcome: Funded acquisition or investor refunds

Phase 5: Asset Acquisition & Operation

Step 11: Title Transfer & Escrow Release

Responsible Party: Legal Counsel & Notary
Process: Legal property transfer to SPV/Trust and fund release from escrow
Verification: Title registration and ownership confirmation
Dependency: Successful funding from Step 10

Step 12: Rent Collection & Distribution

Responsible Party: Property Operations Unit & Treasury Smart Contract
Process: Monthly rent collection → Treasury Escrow → Automated stablecoin distribution to token holders
Technology: Smart contract automation for transparent, proportional distributions
Reporting: Real-time yield tracking and investor dashboards

Phase 6: Secondary Trading & Liquidity

Step 13: Secondary Trading (DEX/CLOB)

Responsible Party: Exchange Partner & Compliance Engine
Process: Enable secondary market trading through decentralized exchange or central limit order book
Compliance: Continuous AML monitoring and trade surveillance
Liquidity: Market-making and price discovery mechanisms

Phase 7: Exit Strategy

Step 14: Exit Strategy Execution

Responsible Party: Governance Board via Smart Contract Voting
Triggers: Predetermined maturity date, market conditions, or investor vote
Process: Property sale → Proceeds distribution to token holders based on fractional ownership
Governance: Transparent voting mechanism for exit decisions

Visual Operational Flow Overview

Complete End-to-End Process Flow

Complete end-to-end operational process flow diagram showing all stakeholders and their interactions

View Alternative Diagram Format

Complete End-to-End Process Flow (Alternative)

Property Owner

Asset Origination

→

SPV/Trust

Legal Structure

↓

Roowang Platform

Governance

↔

Securities Commission

Regulatory Oversight

↓

Blockchain/DLT

Technology

→

Investors

Token Holders

Interactive Stakeholder Matrix

Stakeholder influence and interest matrix showing stakeholder categorization

View Alternative Diagram Format

Interactive Stakeholder Matrix (Alternative)

High Influence, High Interest

Roowang Platform

Influence: 5, Interest: 5

Investors

Influence: 4, Interest: 5

Securities Commission

Influence: 5, Interest: 4

Medium Influence, Medium Interest

Shariah Advisory Board

Influence: 3, Interest: 3

Legal Counsel

Influence: 3, Interest: 3

Compliance Engine

Influence: 3, Interest: 3

Lower Influence, Variable Interest

Treasury Escrow

Influence: 3, Interest: 4

Property Operations

Influence: 2, Interest: 3

Exchange Partner

Influence: 2, Interest: 3

Phase-by-Phase Process Flow

View Alternative Diagram Format

Phase-by-Phase Process Flow (Alternative)

Phase 1: Asset Origination

Step 1: Asset Screening

Step 2: Desktop Valuation

Step 3: LOI Negotiation

Phase 2: Legal Structure

Step 4: SPV/Trust Formation

Step 5: Due Diligence

Phase 3: Technology

Step 6: Token Design

Step 7: Regulatory Sandbox

Step 8: Security Audit

Phase 4: Primary Sale

Step 9: Investor Onboarding

Step 10: Token Sale

Phase 5: Operations

Step 11: Title Transfer

Step 12: Rent Distribution

Phase 6 & 7: Trading & Exit

Step 13: Secondary Trading

Step 14: Exit Strategy

Detailed Stakeholder Ecosystem

Comprehensive stakeholder ecosystem diagram showing all parties and their relationships

Risk & Mitigation Framework

Risk management and mitigation framework diagram

Key Legend

Primary Stakeholders - Core process owners

Governance & Compliance - Oversight & regulation

Technology Infrastructure - Platform & automation

Trading & Investment - Investor-facing services

→Process flow direction

←→Two-way interactions

2. Comprehensive Stakeholder Matrix

Stakeholder	Primary Role	Influence (1-5)	Interest (1-5)	Key Responsibilities	Interaction Points
Property Owner/Developer	Asset origination & sale	3	3	Property supply, SPA execution	Steps 1-3, 11
Roowang Platform (RWG)	Platform governance & operations	5	5	End-to-end process management, compliance	All steps
SPV/Trust	Legal custody & Shariah structuring	4	4	Asset custody, legal compliance	Steps 4-5, 11
Investors	Token purchase & yield receipt	4	5	Capital provision, governance participation	Steps 9-14
Shariah Advisory Board	Halal compliance oversight	3	3	Shariah certification, periodic audits	Steps 4, 6, ongoing
Securities Commission	Regulatory oversight	5	4	Consumer protection, sandbox approval	Step 7, ongoing
Blockchain Provider	DLT contract hosting	3	2	Platform uptime, transaction processing	Steps 6, 8, 12-13
Treasury Escrow (Smart Contract)	Segregated fund management	3	4	Investor fund protection, automated distributions	Steps 10, 12
Compliance Engine	Continuous AML/risk monitoring	3	3	Real-time risk alerts, regulatory reporting	Steps 9, 13, ongoing
Price Oracle	Market data provision	2	2	Real-time property valuations, market feeds	Steps 13-14
Exchange Partner	Liquidity trading facilitation	2	3	Market depth, fair pricing, liquidity	Step 13
Security Auditor	Smart contract verification	2	2	Independent security validation	Step 8
KYC/AML Vendor	Identity verification	2	2	Investor screening, data protection	Step 9
Property Operations Unit	Asset management	2	3	Rent collection, property maintenance, reporting	Step 12, ongoing
External DD Firm	Due diligence services	2	2	Comprehensive property assessment	Step 5
Legal Counsel	Legal structuring & compliance	3	3	Legal documentation, regulatory compliance	Steps 3-5, 11
Chartered Valuer	Independent property valuation	2	2	Professional valuation certification	Step 2

3. Regulatory Compliance & Investor Protection Framework

Core Principles Implementation

Regulatory Principle	Implementation Mechanism	Process Integration	Investor Benefit
Segregated Money Flows	Treasury Escrow Smart Contracts	Steps 10, 12	Investor funds isolated from operational cash
Continuous AML Monitoring	Compliance Engine Integration	Steps 9, 13, ongoing	Real-time risk detection and reporting
Transparent Price Discovery	Price Oracle + Exchange Data	Steps 2, 13-14	Fair, tamper-proof on-chain valuations
Operational Clarity	Defined Stakeholder Matrix	All steps	Clear accountability and audit trails
Shariah Compliance	Advisory Board Oversight	Steps 4, 6, ongoing	Halal investment assurance
Consumer Protection	Sandbox Framework	Step 7, ongoing	Regulatory oversight and recourse

Key Safeguards

Financial Protection

Escrow-based fund segregation
Smart contract automation reducing human error
Independent security audits
Professional insurance coverage

Operational Transparency

Real-time investor dashboards
Automated reporting to regulators
Public blockchain transaction records
Regular compliance audits

Governance Structure

Token holder voting rights
Independent board oversight
Shariah advisory supervision
Regulatory sandbox compliance

4. Technology Architecture & Security

Blockchain Infrastructure

Platform: Regulated DLT provider with high uptime SLA
Smart Contracts: Audited, automated execution of ownership and distributions
Security: Multi-signature wallets, regular security assessments
Scalability: Layer-2 solutions for cost-effective transactions

Compliance Technology

KYC Integration: Automated identity verification with manual review triggers
AML Monitoring: Real-time transaction monitoring and suspicious activity reporting
Regulatory Reporting: Automated compliance reports to Securities Commission
Data Protection: Privacy-by-design with encrypted data storage

5. Risk Management & Mitigation

Risk Category	Potential Issues	Mitigation Strategies
Regulatory	Policy changes, compliance failures	Sandbox participation, legal counsel, regular audits
Technology	Smart contract bugs, platform downtime	Security audits, redundant systems, insurance
Market	Property value decline, liquidity issues	Diversified portfolio, professional management, exit strategies
Operational	Partner failure, process breakdown	Due diligence, SLAs, backup providers
Shariah Compliance	Non-compliant activities	Advisory board oversight, regular certification

6. Key Performance Indicators & Reporting

Investor Metrics

Monthly rental yield distribution
Property appreciation tracking
Liquidity metrics and trading volumes
Portfolio diversification statistics

Compliance Metrics

KYC completion rates and times
AML alert resolution
Regulatory reporting timeliness
Audit findings and remediation

Operational Metrics

Property occupancy rates
Maintenance costs and capital expenditure
Stakeholder satisfaction scores
Technology uptime and performance

Abbreviations & Definitions

Term	Full Form	Description
RWG	Roowang Platform	Primary platform operator
SC	Securities Commission	Malaysian financial regulator
SAB	Shariah Advisory Board	Islamic compliance oversight
SPV	Special Purpose Vehicle	Legal entity holding property
DLT	Distributed Ledger Technology	Blockchain infrastructure
KYC	Know Your Customer	Identity verification process
AML	Anti-Money Laundering	Financial crime prevention
DEX	Decentralized Exchange	Blockchain-based trading platform
CLOB	Central Limit Order Book	Traditional exchange model
LOI	Letter of Intent	Preliminary purchase agreement
DD	Due Diligence	Comprehensive property assessment

roowang

This document provides the comprehensive operational flow and stakeholder mapping requested for the Securities Commission consultation process, demonstrating Roowang's commitment to regulatory compliance, investor protection, and operational transparency in the fractionalized real estate investment space.