Category: Tokenization

  • Project Pine: Lessons Central Banks Can’t Ignore

    Project Pine: Lessons Central Banks Can’t Ignore

    In May, the New York Fed’s Innovation Center and the Bank for International Settlements published the much-trailed Project Pine report, a 57-page technical deep-dive that puts a provocative thesis on the table: even if wholesale finance migrates to tokenised ledgers, central banks can still run the show by wrapping monetary-policy tools inside smart contracts. The prototype paid interest on reserves, conducted standing repos and managed collateral, all on a permissioned Ethereum fork. The takeaway, in the report’s own words, is that “central bank levers remain effective in a fully tokenised settlement landscape.”

    The claim lands at a delicate moment. Every major market infrastructure, from DTCC in the United States to Euroclear in Europe, is experimenting with tokenised bonds and deposits. Advocates argue that smart contracts could cut settlement risk and automate margin calls. Skeptics wonder whether the very act of automating money markets erodes the discretion policymakers rely on when crises hit.

    What Pine actually proved

    The Pine codebase built a generic toolkit: parametric standing repos, interest-on-reserve tokens and an auction algorithm that clears collateral in seconds. Test runs showed the engine could handle normal and stressed liquidity scenarios. In other words, a smart contract can do what the Fed’s open-market desk already does, only faster and without phone calls.

    Importantly, the researchers did not attempt to replicate the Federal Reserve’s full operating framework, nor did they plug the prototype into real Treasury or reserve accounts. Pine is a lab exercise, not a pilot. It answers a narrow question—can we encode the mechanics—while leaving open the bigger one, which is whether code can capture policy-making nuance.

    The discretion problem

    A textbook repo drains or injects reserves at a known rate against known collateral. The real world is messier. In March 2020, the Fed slashed rates, launched unlimited QE and then tweaked the supplementary leverage ratio when banks refused to expand balance sheets. None of those moves followed a predefined script. They required judgment, sequencing and political sign-off, precisely the things smart contracts struggle to model.

    The Pine team argues that contracts can include “central-bank callable” parameters, allowing humans to change rates or collateral haircuts on the fly. That feature solves the narrow governance issue but re-introduces latency, because every parameter update needs to be proposed, audited and pushed to the chain. The advantage over today’s Bloomberg chat messages becomes marginal.

    Tokenised plumbing meets real-world pipes

    A second blind spot is connectivity. The Pine sandbox assumed banks already hold tokenised Treasuries and reserves on a single ledger. In practice, Treasuries sit at the Fedwire Securities Service and reserves live at the Fedwire Funds Service, neither of which is built on blockchain. Any attempt to bridge them introduces settlement risk that today’s tri-party repo providers backstop. Until the pipes are rebuilt, a Pine-style contract would require constant off-chain reconciliations, negating much of the promised efficiency.

    Industry voices are keen to point this out. Dealers on the Securities Industry and Financial Markets Association repo committee note that tokenised collateral could reduce fails but only if the central securities depository tokenises along with the cash side. That is a transformation project, not a code push.

    Monetary control or digital theatre

    The most contentious question is political. Pine suggests that tokenisation need not undermine monetary sovereignty. Crypto purists think the opposite, that on-chain liquidity will route around official money altogether. The truth is likely somewhere in the middle. If tokenised commercial-bank deposits gain market share, central banks can still influence rates through standing facilities, but the transmission might be slower or less predictable. Smart contracts cannot compel borrowers to use them, they can only make liquidity available.

    A telling datapoint is the Fed’s decision, announced the same week as the Pine paper, to start regular morning operations in its standing repo facility. That move echoed April stress when Treasury cash markets wobbled after new tariffs. The tool worked, but only because banks chose to tap it. The episode underlines that liquidity facilities rely on participant behaviour. Putting the same facility on chain will not address the decision calculus banks make when reputational optics collide with funding needs.

    Project Pine lays the groundwork

    None of this means Project Pine is pointless. By mapping central-bank operations into code, the team built a reference design that market infrastructure providers can critique. Banks experimenting with tokenised collateral now have an open-source benchmark. The paper also forces policymakers to articulate guardrails for a future where crypto rails and legacy rails intersect. That conversation is overdue.

    The bigger policy payoff may lie in contingency planning. If tokenised deposits scale faster than expected, regulators will need tools that can plug liquidity holes in minutes, not hours. A Pine-style contract, quality-assured and battle-tested ahead of time, is a better emergency kit than a whiteboard sketch.

    The missing link: Confidence can’t be coded

    Project Pine shows that central banks can translate their existing levers into code, but it does not prove that coded levers will work in the same way when the next liquidity storm arrives. Monetary policy has always blended mechanics with psychology. Smart contracts excel at the former and ignore the latter. Until researchers crack that gap, programmable open-market operations remain an abstraction, interesting for conference decks but a long way from the New York Fed’s trading floor.

    For bankers, fintech engineers and policymakers, the message is cautionary optimism. Tokenisation can streamline money markets, yet the ultimate control knob is still confidence, and confidence is a social contract no blockchain has ever fully automated.

  • Singapore Cracks Down on Foreign-Only Digital Token Services

    Singapore Cracks Down on Foreign-Only Digital Token Services

    On the 6th of June the Monetary Authority of Singapore (MAS) published a terse clarification with outsized impact: from 30 June 2025, any Singapore-incorporated firm that offers digital-token services solely to customers overseas must hold a Digital Token Service Provider (DTSP) licence—or shut down. In the same breath, the regulator warned that such licences will be granted only in extremely limited circumstances,” citing money-laundering risk and the practical impossibility of supervising a business that has no Singapore-facing customer base.

    For years global exchanges and DeFi middle-layers treated Singapore as the perfect corporate perch: English law, deep capital markets, and a regulator friendly enough to issue sandbox exemptions while scrutinising domestic retail flows. The new stance flips that script. Offshore-only models—think liquidity-routing desks, token-issuance vehicles or staking pools headquartered in Singapore but serving India, Vietnam or Africa—now face a three-week countdown to licensing or exile. MAS knows exactly who they are; officials told Asian Banking & Finance they believe the group is “a very small number,” yet the message is aimed at the next wave of founders as much as the current cohort.

    Why MAS Is Pulling Up the Drawbridge

    The decision slots neatly into Singapore’s layering of digital-asset guardrails. Payment Services Act (PSA) licensing in 2020 brought exchange, transfer and custody businesses inside an AML/CFT perimeter. Stablecoin rules in 2023 imposed 100% reserve and audit requirements. Now MAS is closing what lawyers called the “locate-but-don’t-serve” loophole. In its June statement the authority argued that a firm with zero local users is harder to supervise, yet could still launder illicit proceeds through Singapore-based bank accounts. That risk calculus hardened after a S$3-billion money-laundering bust in 2023 that involved shell companies with nominally “foreign only” operations.

    Licensing is theoretically available, but MAS adds a twist: applicants must show “a meaningful nexus to Singapore’s digital-asset ecosystem.” Translation: a board of resident directors, local compliance staff, day-to-day decision-making plus a plan to serve domestic customers eventually. The bar is steep enough that MAS itself expects few, if any, approvals.

    Immediate Fallout: Move, Merge or Morph

    The clearest early signal came hours after the notice: WazirX, an India-focused exchange incorporated in Singapore, said it would redomicile to Panama and spin down its city-state entity before the deadline. Compliance advisers report a surge of calls from token-lending desks and yield-bearing stablecoin issuers asking whether a Cayman foundation plus Hong Kong operating subsidiary might keep Asian banking lines open without MAS approval. Banks, meanwhile, are triaging. One Singapore-based transactional-banking head tells me the “client continuance” review for every offshore-only crypto account is now top priority; cash accounts without a clear licensing path will be closed before MAS has to ask.

    The rule also reverberates through investor term sheets. Venture funds that tout Singapore legal entities as a badge of institutional readiness now face awkward renegotiations. “We liked the MAS halo,” one Series A fintech investor concedes, “but if the halo comes with an unpredictable licensing timeline, we’ll accept a UAE free-zone domicile just as happily.”

    Hub-and-Spoke No More?

    When MAS first floated a DTSP framework in 2022, the objective looked surgical: capture niche businesses such as crypto-on-ramp aggregators or token-issuance advisers that fell between PSA and securities law. Since then the policy mood has darkened. The June clarification states bluntly that the supervisory burden outweighs the benefits when all users sit abroad. Compare that with Hong Kong, which this year approved exchanges that pledge only professional-investor access and largely foreign order flow. Singapore’s pivot therefore redraws the Asian map: Dubai and Abu Dhabi become the obvious shelters for “serve-the-world” exchanges; Hong Kong vies for North Asian order books; Singapore doubles down on institutions, asset-tokenisation pilots and projects like JPMorgan’s Partior—use-cases where regulators can peer into every wallet.

    Data already hint at the divergence. MAS has granted just 16 in-principle approvals and 11 full licences under its Digital Payment Token category since 2020; Hong Kong’s SFC, by contrast, has okayed nine retail-facing exchanges in twelve months. If DTSP approvals prove rarer still, the city-state’s share of global spot-trading volume could fall even as it leads in permissioned pilots.

    What “Licence or Leave” Means for Compliance and Cost

    Obtaining a DTSP licence will not be a PSA redux. According to draft guidelines published last week, applicants must:

    • maintain minimum base capital of S$250,000 (higher if custody is involved);
    • appoint a Singapore-resident CEO and compliance lead;
    • demonstrate end-to-end chain-analysis for every supported token;
    • post an annual auditor’s report in MAS Form 3 within four months of fiscal year-end.

    Firms accustomed to remote-first staffing and offshore custody will need payroll, premises and local audit contracts—hard costs that erode the “light-touch HQ” appeal Singapore once offered.

    The AML bar is higher, too. Name-screening must cover both originator and beneficiary wallets, aligning with the FATF Travel Rule. MAS Notice FSM-N27 (issued alongside the clarification) spells out penalties up to S$1 million for each breach. In short: if a stablecoin desk cannot map wallet addresses to real-world names in real time, it will fail the licence test.

    Policy Rationale vs. Industry Concerns

    MAS insists the impact is contained. Officials told Asian Banking & Finance they see “only a very small number” of affected firms, and those are welcome to apply or pivot. Yet industry bodies counter that innovation suffers when sandbox graduates cannot scale globally from Singapore. The Singapore FinTech Association warns of a “talent drain” if engineers move with their employers to more permissive hubs. Lawyers note a tension: MAS promotes Project Guardian—its high-profile asset-tokenisation pilot with HSBC and UBS—while shutting the door on retail-lite crypto models that could feed liquidity to those very projects.

    MAS’s reply is unambiguous: quality over quantity. The regulator would rather host fewer, better-capitalised players than police a long tail of offshore profit centres. That stance dovetails with broader reputational goals after last year’s money-laundering scandal and ongoing U.S. pressure to tighten crypto AML standards.

    Comparison with Other Gateways

    JurisdictionLicence for offshore-only models?Typical approval timeNotable hurdles
    Singapore (DTSP)Yes, but “generally not issued”n/a (yet)Resident CEO, granular travel-rule compliance, capital S$250k+
    Hong Kong (VATP)Yes6-9 months98-point checklist, mandatory insurance, local cold-wallet storage
    Dubai (VARA MTL)Yes4-6 monthsTiered licence fees up to US$140k, substantial physical presence
    UK (FCA Crypto-asset register)Yes12-18 monthsAML focus, tough business-model scrutiny but no local-customer requirement

    For start-ups the lesson is that regulatory arbitrage is narrowing. A Singapore entity can still run offshore custody or marketing, but only with an MAS badge—otherwise founders might as well incorporate where that badge is easier to earn.

    What to Watch Before 30 June

    • Licence applications: MAS will reveal by mid-July how many firms applied; the number will signal whether industry views approval as plausible or pointless.
    • Bank de-risking: Expect local banks to demand DTSP licence evidence before extending credit lines beyond the deadline.
    • Migration wave: Tracker sites already log half-a-dozen Singapore entities reincorporating in the UAE and Panama.
    • Institutional pilots: Will MAS grant carve-outs for projects like tokenised Treasury repo platforms that currently serve offshore desks?

    The Bottom Line

    Singapore hasn’t slammed the door on crypto; it has narrowed the doorway to actors it can supervise face-to-face. For retail-lite exchanges, offshore staking pools and token-issuance SPVs, the message is blunt: become part of Singapore’s domestic ecosystem or pack your bags. Neat corporate structures that once signalled credibility now trigger higher scrutiny. As global regulators converge on AML expectations, the city-state is betting that being the well-lit room for digital assets is worth losing a few tenants who prefer the dark. Whether that bet lures more blue-chip tokenisation projects—or drives them to less demanding jurisdictions—will shape Asia’s crypto geography for years to come.