Single-jurisdiction legal anchor
Regulatory framework.
Tortuga is not an unregulated product wrapped in a compliance layer for marketing purposes. The underlying instruments are issued securities under Luxembourg law, carry Swiss ISINs, and trade as ERC-3643 permissioned tokens where transfer eligibility is enforced at the smart-contract level on every transaction.
Luxembourg Law of 22 March 2004 (as amended)
The Securitisation Act is the enabling statute for Tortuga's issuing vehicle. Estating Property Vault S.A. is a regulated Société de Titrisation; each issuance is a ring-fenced compartment.
Compartments are bankruptcy-remote from one another and from the sponsor. Noteholders in one compartment have no recourse to assets in another. The 25 February 2022 amendments extended the eligible asset universe and introduced institutional-grade governance requirements.
The Luxembourg CSSF supervises the sector under this law. Tortuga's AML/KYC regime aligns with CSSF Circular 18/698 via SumSub.
MiFID II — Directive 2014/65/EU
Distribution of financial instruments across the EU under the passporting regime. Tortuga's distribution partners operate under their own MiFID authorisations; Tortuga does not provide investment advice.
View on EUR-Lex →Prospectus Regulation — Regulation (EU) 2017/1129 + EU Listing Act (EU) 2024/2809
Offering thresholds determine when a full prospectus is required. Below thresholds, offering memorandum + final terms suffice for distribution to qualified investors.
From 5 June 2026, the EU Listing Act harmonises the threshold at €12M. Poland retains a €5M national threshold for certain categories.
ERC-3643 compliance alignment
The ERC-3643 (T-REX) standard maps directly to the legal perimeter: Identity Registry (whitelisting), Compliance Module (jurisdiction + investor-type checks), and canTransfer() enforcement. The token is a permissioned representation of the underlying bond, not a separate instrument.
CSSF posture
The Luxembourg CSSF is the primary supervisor. Tortuga's AML/KYC framework, source-of-funds checks, and sanctions screening align with CSSF Circulars 18/698 and 17/650. Touchpoints include the securitisation vehicle registration and the professional-investor certification regime.