Institutional Tokenization Adoption: Bank-by-Bank Tracker
Every major global bank has a tokenization program. What varies dramatically is scale, regulatory framework, and strategic ambition. This tracker documents what each institution has actually built — not announced — with current scale and compliance context.
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This tracker documents the tokenization programs of 10 major financial institutions as of Q1 2026. For each institution, we cover: what was built, at what scale, on which blockchain infrastructure, under which regulatory framework, and what the strategic direction indicates about near-term development.
“What was built” means production programs with disclosed AUM, transaction volume, or client count — not pilots, proofs of concept, or announcements without follow-through. The institutional tokenization landscape contains many announced programs that have not progressed to production scale; those are not included here.
BlackRock
Program: BlackRock USD Institutional Digital Liquidity Fund (BUIDL)
Scale: $1.7 billion AUM (Q4 2024)
Infrastructure: Ethereum (primary), Polygon, Avalanche, Aptos, Arbitrum, Optimism (via wrapped tokens). Transfer agent: Securitize.
Regulatory framework: US Investment Company Act (registered fund). Offered under Regulation D (private placement to qualified purchasers). Minimum investment: $5 million. US Reg D only — non-US investors via Regulation S.
What it does: BUIDL is a tokenized money market fund investing in US government securities, cash, and repo. Daily yield accrual via rebasing; monthly USDC settlement. Token is a permissioned ERC-20 — transfers restricted to Securitize-whitelisted addresses.
Strategic direction: BlackRock has publicly stated that tokenization of financial assets is a “next generation for markets.” Larry Fink’s 2024 letter to investors explicitly identified tokenization as a core strategic theme. BUIDL is the production expression of this strategy. BlackRock’s partnership with Securitize extends to multiple other tokenized fund products in development, including tokenized equity fund interests for private market strategies.
Compliance context: BUIDL’s compliance architecture is the institutional reference model. BNY Mellon conventional custody of underlying assets; PwC audit; SEC reporting; smart contract permissioning for AML enforcement. See the full BUIDL analysis.
JPMorgan
Program: Onyx Digital Assets — tokenized repo; JPM Coin; blockchain-based collateral settlement
Scale: $1 billion+ daily transaction volume through JPM Coin (wholesale payment system); $1.5 billion+ in tokenized collateral settled through Onyx repo platform (2023 peak)
Infrastructure: Onyx is built on Quorum (JPMorgan’s enterprise Ethereum fork), operated as a permissioned private blockchain. JPM Coin operates on Onyx for wholesale payment settlements between institutional counterparties.
Regulatory framework: JPM Coin is not a security — it is a wholesale payment instrument operating under JPMorgan’s banking license. Tokenized repo and collateral settlement operate as conventional securities transactions with DLT as the settlement layer, under existing securities law frameworks.
What it does: Three primary functions. JPM Coin enables institutional clients to move dollar-denominated value 24/7 through JPMorgan’s settlement network — used for intraday liquidity management by large institutional clients. The Onyx repo platform enables intraday repo transactions with DLT-based settlement finality, eliminating the T+2 settlement lag of conventional repo markets. The collateral settlement network allows institutional counterparties to post and receive collateral (including tokenized Treasury and agency securities) in near-real-time.
Strategic direction: JPMorgan has been the most active bank in building tokenization infrastructure at institutional scale. The Onyx platform is used by Goldman Sachs, BNY Mellon, and other major institutions for repo and collateral transactions. In 2023, JPMorgan joined the Partior network (a global payment network built on DLT) alongside DBS Bank and Standard Chartered.
Compliance context: All Onyx activities operate within JPMorgan’s existing banking regulatory framework (OCC chartered bank, Federal Reserve regulated). The tokenization layer does not alter the regulatory classification of the underlying transactions.
Goldman Sachs
Program: GS DAP (Goldman Sachs Digital Asset Platform) — tokenized bond issuance and repo
Scale: €100 million+ in tokenized bond issuances (European Investment Bank bond, 2022; multiple corporate issuances through 2024); significant repo volume on Onyx network
Infrastructure: Goldman’s GS DAP is built on a permissioned blockchain. For the EIB bond and several other issuances, Goldman used a private chain. Goldman is also a major user of JPMorgan’s Onyx network for repo.
Regulatory framework: Tokenized bond issuances have been structured under European securities law (for the EIB transaction, Luxembourg and French securities law). GS DAP operates under Goldman Sachs’s existing regulatory permissions (broker-dealer in the US, authorized investment firm in the EU).
What it does: GS DAP enables digital issuance of debt securities — the bond is issued as a digital token on a DLT ledger rather than through a conventional CSD. Settlement occurs on-chain in real time (or intraday), eliminating the settlement risk inherent in T+2 conventional settlement. Secondary trading is facilitated through the platform among approved institutional counterparties.
Strategic direction: Goldman has been deliberate rather than rapid in its tokenization build-out. Its focus is on high-value institutional debt capital markets transactions — bond issuances, repo, collateral management — where the settlement efficiency gains from DLT are most economically significant. Goldman has publicly stated plans to expand GS DAP to additional asset classes including fund interests and private market securities.
Compliance context: GS DAP transactions are structured as conventional securities under applicable law. The DLT layer is treated as an operational innovation, not a regulatory one. Goldman applies its existing MiFID II/securities law compliance framework to all GS DAP transactions.
HSBC
Program: HSBC Orion — tokenized bond issuance; tokenized gold (HSBC Gold Token)
Scale: Several tokenized bond transactions totaling $1 billion+ (including Hong Kong government bonds); HSBC Gold Token: physical gold tokenization program for institutional clients in HK
Infrastructure: HSBC Orion is an in-house DLT platform built by HSBC’s technology team. For some transactions, HSBC has used the public Ethereum network (with permissioning layers). HSBC Gold Token operates on the HSBC Orion infrastructure.
Regulatory framework: HSBC Orion bond issuances in Hong Kong operate under the SFC’s framework for digital securities. The Hong Kong Monetary Authority (HKMA) has actively encouraged HSBC’s tokenization program as part of Hong Kong’s digital asset strategy. HSBC Gold Token is structured as a tokenized commodity product under HKMA/SFC guidance.
What it does: Orion enables HSBC to act as lead manager for digitally issued bonds, where the bond documentation, investor register, and settlement instructions are managed on the DLT platform. Secondary trading is facilitated through Orion among approved counterparties. HSBC Gold Token provides institutional clients with tokenized exposure to physically allocated gold held in HSBC’s vaults — 1 token = 0.001 troy ounce of physical gold, with delivery rights.
Strategic direction: HSBC has positioned Hong Kong as the hub for its tokenization activities, consistent with its broader Asia-focused strategy. The bank’s close relationship with HKMA gives it a regulatory engagement advantage in Hong Kong that most foreign banks do not have.
UBS
Program: UBS Tokenize — tokenized structured products; UBS VCC tokenized fund (Singapore)
Scale: CHF 370 million in tokenized structured notes (2023–2024); Singapore VCC tokenized fund pilot
Infrastructure: UBS Tokenize uses a hybrid approach: on-chain representation of securities with conventional CSD (SIX Digital Exchange in Switzerland) as the legal settlement layer.
Regulatory framework: Swiss tokenized structured notes issued under FINMA’s DLT-accommodating regulatory framework and listed on the SIX Digital Exchange (SDX), Switzerland’s regulated digital securities exchange. Singapore VCC (Variable Capital Company) tokenized fund pilot conducted under MAS sandbox with Project Guardian.
What it does: UBS issues tokenized structured notes — typically short-duration, capital-protected notes linked to equity or rate indices — where the note is issued as a digital security on SDX. Institutional investors can trade the tokenized note through SDX’s regulated secondary market. The Singapore pilot involves tokenizing interests in a VCC-structured fund for institutional distribution.
Strategic direction: UBS is leveraging its existing strength in structured products and its Swiss home regulatory advantage. SDX’s regulatory status as a FINMA-licensed DLT Trading Facility provides the legal infrastructure that UBS needs to issue and trade digital securities at scale.
Societe Generale
Program: SG-Forge — tokenized covered bonds; MakerDAO integration; EUR CoinVertible (EURCV)
Scale: €100 million+ in tokenized covered bonds (OFH tokens); EUR CoinVertible issued as institutional euro stablecoin
Infrastructure: SG-Forge primarily uses public Ethereum, with compliance layers provided by SG-Forge’s permissioning infrastructure. EURCV is an ERC-20 stablecoin.
Regulatory framework: OFH tokens (tokenized covered bonds) issued under French law and registered with Euroclear France as the conventional CSD. SG-Forge holds a PSAN registration with the French AMF (the pre-MiCA registration regime) and is transitioning to MiCA CASP authorization.
What it does: SG-Forge’s most notable transaction was its 2023 proposal to MakerDAO to use OFH tokens (tokenized covered bonds backed by French home loans) as collateral in the MakerDAO protocol — one of the first direct integrations of a bank-issued tokenized security into a DeFi lending protocol. EURCV is an institutional euro stablecoin designed for use in DeFi protocol settlements, wholesale FX, and collateral management.
Strategic direction: SG-Forge is the most DeFi-integrated of the major European bank tokenization programs. Its willingness to engage directly with MakerDAO governance and DeFi protocol infrastructure reflects a strategic conviction that the DeFi ecosystem is a legitimate institutional distribution channel.
Deutsche Bank
Program: Deutsche Bank digital securities custody; Project Guardian participation
Scale: Regulatory approval obtained from BaFin for crypto custody operations; disclosed participation in Singapore MAS Project Guardian
Infrastructure: Deutsche Bank has obtained a BaFin crypto custody license (Kryptoverwahrgeschäft) under the KWG. Project Guardian involvement uses Singapore MAS-supervised infrastructure.
Regulatory framework: German banking law (KWG) for crypto custody; Singapore MAS Project Guardian for tokenized fund distribution pilots.
What it does: Deutsche Bank’s crypto custody license enables it to provide regulated custody of digital assets for institutional clients, potentially including tokenized securities. Project Guardian participation involves Deutsche Bank acting as a liquidity provider or distribution participant in MAS-supervised tokenized fund experiments.
Strategic direction: Deutsche Bank has been more measured in its tokenization program than JPMorgan or Goldman. The BaFin custody license positions it to offer institutional custody services as tokenized asset demand grows among European clients.
Standard Chartered
Program: Zodia Markets (crypto prime brokerage); Zodia Custody; Partior network participant
Scale: Zodia Custody launched 2023 with institutional client onboarding; Partior network for real-time cross-border settlement
Infrastructure: Zodia Custody uses HSM-based cold storage infrastructure. Partior is a Singapore-incorporated DLT-based payment network using a permissioned blockchain.
Regulatory framework: Zodia Custody is regulated by the FCA in the UK (AML registration). Standard Chartered’s Singapore operations are MAS-regulated. Partior operates under the MAS’s payment services framework.
What it does: Zodia Custody provides institutional-grade custody for digital assets, including tokenized securities. The Partior network — co-founded by Standard Chartered, JPMorgan, and DBS — enables real-time, 24/7 cross-border payment settlement for institutional clients in Singapore dollars, US dollars, and euros, using blockchain for settlement finality.
Strategic direction: Standard Chartered has focused on infrastructure (custody, cross-border settlement) rather than issuance. Its Partior participation reflects a view that wholesale cross-border payment settlement is the highest near-term value use case for DLT in banking.
Citi
Program: Citi Token Services — tokenized deposits and trade finance; cross-border settlement pilots
Scale: Citi Token Services launched 2023; $10 billion+ in tokenized deposit movement facilitated through pilot programs; trade finance pilots with Canal de Panama and Maersk
Infrastructure: Citi’s tokenization infrastructure uses a permissioned blockchain for internal settlement. Cross-border pilots use blockchain for settlement instruction transmission with conventional correspondent banking for final settlement.
Regulatory framework: Tokenized deposits operate under Citi’s existing banking licenses. The OCC has provided guidance that nationally chartered banks may use DLT for payment activities, which provides the regulatory basis for Citi’s tokenized deposit operations.
What it does: Citi Token Services creates tokenized representations of client deposits that can be transferred between Citi branches globally in real time — enabling 24/7 liquidity management for multinational clients. The trade finance pilot tokenized bill of lading and letter of credit documents, enabling real-time document exchange and settlement triggering.
Strategic direction: Citi’s focus on tokenized deposits reflects its view that wholesale payment and liquidity management is the highest near-term value use case for tokenization in global banking. This is a narrower focus than JPMorgan’s Onyx but may be more immediately implementable at scale.
BNY Mellon
Program: Digital Asset Custody; tokenized fund administration (including BUIDL custody)
Scale: Launched digital asset custody in October 2022 (first US systemically important bank to do so); provides conventional custody services underlying multiple major tokenized fund programs including BlackRock BUIDL
Infrastructure: BNY Mellon’s digital asset custody platform uses a combination of cold storage hardware and HSM-based key management, integrated with its conventional custody infrastructure.
Regulatory framework: BNY Mellon’s crypto custody operates under its New York State banking charter (NYDFS regulated) and its national trust company charter. The OCC and NYDFS have both confirmed that nationally chartered banks may provide crypto custody under their existing charters.
What it does: BNY Mellon provides conventional custody for the underlying securities portfolios of tokenized funds, including BlackRock BUIDL. It also provides direct digital asset custody for institutional clients, holding private keys for tokenized assets. As the world’s largest custodian ($49 trillion+ in AUM under conventional custody), BNY Mellon’s entry into digital asset custody has significant market signaling value.
Strategic direction: BNY Mellon is positioning itself as the custody backbone for the tokenized asset industry — providing both conventional custody for the underlying assets and digital asset custody for the token layer. This “custodian of the tokenized world” strategy leverages BNY’s existing institutional relationships and regulatory standing.
Patterns Across the Institutional Landscape
Several patterns emerge from this institution-by-institution review:
Infrastructure vs. distribution: Institutions divide into those building tokenization infrastructure (JPMorgan Onyx, BNY Mellon custody, Standard Chartered Partior) and those focused on tokenized product distribution (BlackRock BUIDL, Goldman GS DAP, UBS Tokenize). The infrastructure providers are building the rails; the distribution players are putting product on the rails.
Regulatory framework of choice: No major institution has built a tokenization program that requires regulatory novelty. Every program uses existing legal categories — registered investment company, covered bond, secured deposit, conventional securities — with blockchain as the operational layer. Regulatory risk has been systematically avoided.
Public vs. private blockchain: JPMorgan, Citi, and Standard Chartered favor permissioned private blockchains for institutional applications. BlackRock, Goldman, and SG-Forge have used public Ethereum (with permissioning layers). UBS uses Switzerland’s regulated exchange infrastructure (SDX). The public/private blockchain choice reflects differing institutional risk tolerances for public blockchain auditability and decentralization.
Geographic focus: US institutions (BlackRock, Goldman, JPMorgan, BNY Mellon, Citi) build primarily for US regulatory frameworks, with separate international programs. European and Asian institutions (HSBC, UBS, SG, Deutsche, Standard Chartered) leverage their home regulatory advantages (MiCA, FINMA, MAS, SFC).
Related Resources
- BlackRock BUIDL: Detailed Analysis
- Global Tokenization Market Overview 2026
- Platforms Database
- Regulatory Benchmarks
- Jurisdiction Comparison
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