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This year’s convening took place at a pivotal moment for digital finance. The passage of landmark stablecoin legislation in the United States, the release of global peer reviews on crypto-asset regulation, and rapid advances in artificial intelligence have collectively shifted the conversation from abstract potential to practical implementation. Across two days, leaders from central banks, supervisory agencies, international standard-setters, financial institutions, technology firms, academia, and civil society came together to ask not only what is possible, but what is prudent—and how to move from experimentation to durable, trusted systems.

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The results of a working group reported on the legal certainty of collateral eligibility and the mobility of Tokenized Money Market Funds (TMMF) in Luxembourg, Ireland, and the UK. Ireland and Luxembourg host more than 80% of the MMFs and cross-border funds in Europe and English law governs the Credit Support Annex (CSA).

The report concludes:

• There is relative legal certainty of TMMFs located in Luxembourg in a digitally native or registered form due to the availability of statutory frameworks to govern such transactions
• Longstanding historical legal interaction between Luxembourg and the UK in respect of financial and investment contractual arrangements, including CSAs, also makes this an attractive place to establish a TMMF where the tokens will be posted as collateral under a CSA governed by English law
• There is not yet express statutory or judicial authority in Ireland specifically addressing tokenized shares or TMMFs. Legal certainty in respect of ownership and treatment of tokenized shares under Irish law therefore requires an analogy to traditional shares and electronic contracts, rather than being directly established
• It is reasonable to conclude that Irish courts would treat digitally native TMMF shares in a manner consistent with traditional shares. This alignment reinforces the view that TMMF shares can be accommodated within existing property law principles in Ireland, supporting their recognition and enforceability under Irish legal standards
• Where an MMF is tokenized using a digitally native TMMF and is located in the UK, there is a low degree of legal uncertainty concerning the legal treatment of ownership and a similarly low level of uncertainty concerning the replication of rights for market participants between the traditional MMF and a digitally native TMMF
• It is anticipated that further certainty will be available in the UK if the Property (Digital Assets etc.) Bill is enacted and common law precedent is developed as to the implications of the “third category” of property.

Over 70 firms participated in the working group including S&P, Federated Hermes, R3, JP Morgan, Ownera, Finastra, Lloyds Banking Group, Hogan Lovells, LSEG, Archax, Blackrock, State Street, ISDA, EY, Commerzbank, Fireblocks, Northern Trust, Apex Group, Franklin Templeton, and Goldman Sachs.

As part of the working group 30 of the firms participated in the GDF Industry Sandbox, powered by Ownera, the firm which operates the FinP2P routers that implement the open FinP2P standard to “prove” the production use case for collateral mobility in TMMFs.

With no fundamental barriers identified across legal, operational and regulatory dimensions, the sandbox demonstrated that TMMFs can transition from theoretical use cases to a production-ready collateral instrument across six simulations:

• Simulation 1: Simple Bilateral Transfer – Manual Margining of TMMFs
• Simulation 2: Integrated Margin Calls – Automated Posting via Third-Party Systems
• Simulation 3: Depeg Event and Substitution – Dynamic Portfolio Management
• Simulation 4: Default Scenario – Enforcement and Recovery in Insolvency
• Simulation 5: Funding of TMMF in Triparty
• Simulation 6: From SWIFT to Collateral Settlement in Seconds.

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Key report highlights include:

• DLT is ready to scale: Institutional adoption is accelerating, with tokenized money market funds and digital bond issuances gaining traction globally.
• Technology-neutral regulation is essential: The Joint Trades emphasize that prudential frameworks must focus on the underlying financial activity and risk—not the technology used. Overly conservative capital treatments for cryptoassets risk pushing innovation outside the regulatory perimeter.
• Legislation and regulation must catch up: Reform needs to keep pace with development of DLT-based finance and market developments.
• DLT enables safer, more efficient markets: Use cases such as collateral management, fixed-income issuance, and fund tokenization demonstrate reduced settlement times, improved liquidity, and enhanced operational resilience.

Six priority areas for ecosystem development identified in the report include:

1. Accelerate market development in high-potential asset classes.
2. Clarify legal foundations and align regulatory treatment.
3. Establish interoperability to prevent market fragmentation.
4. Address technical and operational integration gaps.
5. Enable scalable settlement with tokenized money and stable payment instruments.
6. Foster public-private coordination.

The stage for mass adoption of tokenization in capital markets is set, driven by clearer regulatory pathways, mature technology platforms and committed institutional participation. Now is the time for coordinated action to harness the benefits of DLT, modernize financial infrastructure and support sustained economic growth.

The full report and executive summary, as well as deep-dives for each of the use-cases are available for download below.

About the Associations
The Associations include the Global Financial Markets Association (GFMA) and its members the Asia Securities Industry & Financial Markets Association (ASIFMA), Securities Industry and Financial Markets Association (SIFMA) and the Association for Financial Markets in Europe (AFME); Bank Policy Institute (BPI); Futures Industry Association (FIA); Financial Services Forum (FSF); Global Blockchain Business Council (GBBC); Global Digital Finance (GDF); Institute of International Finance (IIF); International Swaps and Derivatives Association (ISDA).

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As the deadline approaches, firms continue to face operational bottlenecks that risk undermining the Travel Rule’s objectives. In particular, persistent issues around protocol interoperability, self-hosted wallet (SHW) verification, and counterparty due diligence are creating fragmentation and compliance uncertainty across Europe’s digital asset landscape.

This paper reflects input from surveyed CASPs across Europe and proposes six clear and actionable recommendations:

1. Extension of the transitional deadline
2. Establishing a permanent public-private Working Group
3. Suggesting a transitional regime to full enforcement of provisions pertaining to the verification of SHWs’ ownership
4. Taking a risk-based approach to SHW obligations
5. The EU should support and promote the development of a harmonised and publicly accessible register of licensed VASPs to facilitate basic verification and enhance the risk assessment across jurisdictions, reducing reliance on direct outreach and case-by-case inquiries.
6. Encouraging the NCAs and European Authorities to ensure legal consistency in the application of these rules

GDF remain committed to working with EU authorities, national regulators, and our industry partners to ensure the Travel Rule is implemented in a way that is effective, scalable, and innovation-supportive.

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As tokenization gains momentum in financial markets, digital asset custody lies at the very heart of this transformation. Yet, with this evolution comes complexity.

Under the co-chairship of Deloitte and Zodia Custody, the GDF Digital Asset Custody x Tokenization Working Group set out to analyze these complexities and shed light onto how, in a tokenized financial system, custody is not just about safekeeping – it becomes a gateway to interoperability, compliance and, ultimately, trust. Custodians are being asked to do more than ever before: integrate with smart contracts, support cross-chain infrastructure, safekeep private keys and manage these on-chain assets’ programmable features and real-time settlement mechanics.

Industry dialogue facilitated through this Working Group and subsequent report examines how custody models are evolving to meet these demands and what it means for the future of institutional tokenization, and highlights areas where greater clarity, coordination, and standardization could meaningfully advance adoption.

With that in mind, this report sets out four areas for consideration for industry stakeholders, regulators, and policymakers – all outlined in further detail in the report:

1. Clarify the Legal Status of Digital Books & Records,
2.  Improve Cross-Jurisdictional Understanding of DLT Recognition,
3. Promote Consistent Risk-Weighted Capital Treatment, and
4. Enhance Transparency Around Custody Liability and Operational Risk.

GDF looks forward to continued engagement with both the private and public sectors to support unlocking the full benefits of tokenized finance in capital markets enabled by robust digital asset custody services.

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