Singapore’s Project Guardian Releases Playbook for Operationalising Tokenised Funds
There’s a fundamental shift slowly taking place in the asset management space. While global money market funds hold close to US$10 trillion in assets, tokenised funds’ AUM sits at a few billion dollars, according to the CFA Institute.
But that gap is precisely what makes this moment interesting. The question is less about whether tokenisation will scale, but more about how the infrastructure, legal frameworks, and operational playbooks will need to evolve to make it happen.
The Guardian Asset & Wealth Management Industry Group’s recent report, “Operationalising Tokenised Funds”, cuts through to examine what actually needs to work.
It shares insights on how firms can build legally sound structures, select the appropriate settlement assets and connect across a fragmented blockchain landscape.
Three Models for Tokenised Fund Structures
According to the report, the cornerstone of any tokenised fund is its legal structure. A central question is how ownership is represented and transferred, an area where tokenisation introduces meaningful change.
In traditional fund structures, this question has a clear answer: ownership exists in an off-chain register maintained by an administrator. That register is the single source of truth.
Tokenisation destabilises this certainty. Now ownership could be recorded on-chain as a mirror of the official register, as a parallel record, or as the sole legally recognised source, with the blockchain serving as the authoritative record.
Each approach carries significant implications for investor rights, regulatory compliance and operational risk.
The report outlines four models of tokenisation, grouped under three broader archetypes of tokenised fund share register forms: Digital Mirror, Digital Twin (Distributor and Feeder Fund), and Digital Native models.
Source: Operationalising Tokenised Funds, Project Guardian
The choice between these models could fundamentally shape the legal, operational, and regulatory architecture of the fund. Digital Mirror implementations offer a conservative entry point, preserving existing legal frameworks while exploring blockchain’s operational benefits.
Digital Twin structures represent a middle ground, while Digital Native funds, in contrast, represent a more radical departure as they retain a blockchain-only register.
Stablecoins Gain Ground, With Caveats
According to the Operationalising Tokenised Funds report, well-regulated stablecoins are increasingly used as settlement assets for tokenised products, including tokenised money market funds (tMMFs). 2025 marks an inflexion point, largely thanks to regulatory clarity enabled by frameworks like the United States’ GENIUS Act.
Stablecoins have also become critical in cross-border payments, especially in emerging markets where currency volatility, large unbanked populations, and high transfer costs make traditional rails inefficient.
But that utility doesn’t erase the risks. Regulators and investors must still consider risks like the potential for de-pegging when the value of the underlying assets fluctuates.
Crucially, not all stablecoins are created equal. Those with transparent, provable reserves, independent audits and full backing by cash or cash equivalents are far more likely to gain institutional acceptance as credible settlement assets.
Regulatory frameworks are catching up accordingly. Singapore and Hong Kong, among others, have introduced or are developing specific rules for stablecoins and cryptoassets.
MAS, for example, has implemented a stablecoin framework that requires issuers to meet standards for value stability, reserve management and redemption policies.
Clear and consistent regulation is essential for stablecoin adoption, giving institutional investors the confidence to integrate them into regulated financial infrastructure.
But alignment with global standards from bodies like the FSB and BIS will be critical to preventing regulatory arbitrage as adoption scales. Without it, jurisdictional fragmentation could undermine the stability these frameworks aim to ensure.
Tokenised Deposits Emerging as a Regulated Alternative
Multiple commercial banks are now exploring and issuing tokenised deposits as an alternative to stablecoins or CBDCs, such as HSBC.
These instruments are on-chain representations of traditional bank deposits, created and managed within fully regulated banking environments. They offer the potential for faster settlement, lower counterparty and settlement risk, and greater security and transparency compared to traditional payment rails.
Whether tokenised deposits can compete with stablecoins’ network effects, or whether they remain a conservative option, is still an open question.
wCBDCs Are Taking Shape as the Institutional Settlement Rail
If stablecoins are the pragmatic choice and tokenised deposits the conservative hedge, wholesale Central Bank Digital Currencies (wCBDCs) represent the structural shift.
Issued by central banks for use by commercial banks and authorised financial institutions, wCBDCs are designed for high-value interbank payments and securities settlement. A 2024 BIS survey found that wCBDCs are currently the most widely used settlement asset in tokenisation pilots, ahead of both tokenised and non-tokenised deposits.
Their role mirrors that of central bank reserves in today’s system, while adding new features such as programmability and composability, making them a strong candidate for tMMF settlement, particularly within distributor-led models.
Overall, regardless of the settlement asset chosen, the playbook shares that financial institutions will need to build the supporting infrastructure.
This includes secure digital custody, efficient on- and off-ramps, compliant digital wallets for handling assets and settlement tokens, and robust KYC and AML processes to meet regulatory expectations.
What It Will Take for Tokenised Funds to Scale
Scaling tokenised funds will take more than blockchain efficiency. While the technology is inherently scalable, applying it to regulated financial markets introduces challenges around compliance, operations and interoperability.
Onboarding and Compliance Must Become Simpler
Mainstream adoption depends on frictionless, compliant onboarding. Firms must still meet KYC, AML, CFT and sanctions requirements, which are difficult to automate on-chain.
Today, most platforms rely on whitelisting wallet addresses individually. They rely on their existing KYC onboarding process, during which the client submits a wallet address that is then added to the allowlist.
Select models using digital identity and verifiable credentials are emerging, but will require strong industry governance around credential issuance, validation and revocation before they can be widely adopted.
More of the Fund Lifecycle Needs to Move On-Chain
Fund managers are beginning to migrate parts of the fund lifecycle on-chain for efficiency. But a fully digital-native ecosystem is still some distance away, insights from the report indicate.
Tokenised funds still rely heavily on traditional on/off-chain functions such as custody, transfer agency and fund administration.
To reach true scale, on-chain platforms should support efficient issuance, record-keeping, subscriptions, redemptions and corporate actions, and deliver value beyond what existing processes already provide.
New Operational Risks Require New Safeguards
Tokenised finance introduces risks not found in traditional markets. Smart contracts underpin most processes and require rigorous testing, upgrade controls and monitoring.
Digital custody and key management add another layer of complexity. Public-chain consensus models also introduce new forms of settlement and finality risk.
Institutions will, therefore, need strong operational safeguards, including secure key frameworks, multi-sig or MPC wallets, fallback mechanisms and clear recovery processes.
Interoperability and Standards Will Unlock Scale
Institutional adoption increasingly depends on reaching liquidity across multiple chains. This requires reliable cross-chain communication, standardised messaging formats (such as ISO 20022 and the Common Domain Model), and consistent APIs to support custody, settlement and lifecycle management.
The industry is also laying the groundwork for broader interoperability through efforts such as FIX standards into smart contract integration, cross-chain protocols and oracle networks. These standards are essential if tokenised markets are ever to reach the seamless interoperability moment that email achieved with SMTP.
Privacy-preserving tools like zero-knowledge proofs will strengthen security and compliance, while ongoing research into post-quantum cryptography will prepare blockchain systems for future threats.
Meanwhile, smart-contract standards across EVM-compatible chains will continue to support composability and cross-network functionality.
Project Guardian’s Operationalising Tokenised Funds report makes the direction clear: the question is no longer whether tokenised funds will reshape the asset management industry, but how quickly institutions can prepare for this shift.
Featured image edited by Fintech News Singapore based on image by thanyakij-12 on Freepik
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