Institutional Tokenization Adoption Tracker: Bank and Asset Manager Progress

In 2020, institutional tokenization was a lab project. In 2022, it was a pilot programme. In 2024, it became infrastructure. BlackRock’s BUIDL fund crossed $1.7 billion, JPMorgan’s Kinexys processed $2 billion in daily volume, and Broadridge’s DLT Repo platform crossed $1 trillion in cumulative notional. The question for compliance teams is no longer whether institutional tokenization will happen but how to build the compliance programmes that allow institutions to participate in it safely.

This tracker maps the deployment status, platform choices, asset classes, and regulatory positioning of the world’s major institutional tokenization programmes.

Asset Managers: Deployed

BlackRock — BUIDL Fund (USD Institutional Digital Liquidity Fund)

Status: Deployed. Operational since March 2024.

Platform: Ethereum (public, permissioned access via Securitize). Securitize acts as transfer agent and broker-dealer; both entities are SEC-registered.

Structure: Regulation D exempt offering. Qualified purchasers only. Minimum subscription $5 million. Fund invests in US Treasury bills, cash, and repo. BUIDL token represents a fund share; daily income distribution accrues on-chain and is settled periodically in USDC.

AUM: $1.7 billion within months of launch; continued growth through 2024-2025.

Compliance architecture: The BUIDL programme represents what this publication regards as the institutional compliance template for tokenized funds. The choice of Securitize — an SEC-registered transfer agent and broker-dealer — as the compliance infrastructure layer means that every token transfer is validated against a whitelist of verified qualified purchasers, with transfer agent records maintained off-chain in parallel. Unwhitelisted wallets cannot receive BUIDL tokens; the transfer restriction is enforced at the smart contract level, consistent with Regulation D resale restrictions.

Regulatory positioning: BlackRock’s public positioning — emphasising Securitize’s registered status, the Regulation D structure, and the institutional-only access — was deliberate. It sent a signal to regulators that institutional tokenization could be done within existing frameworks without requiring new legislation. This signal has been heard: the SEC has not challenged the BUIDL structure.

Franklin Templeton — BENJI (Franklin OnChain US Government Money Fund)

Status: Deployed. Operational since 2021 (Stellar), expanded 2023-2024.

Platform: Stellar blockchain (primary), Polygon, Arbitrum, Base, Aptos (subsequent deployments).

Structure: Registered investment company (1940 Act fund), not a Reg D exempt offering. This is a material distinction from BUIDL: BENJI is a publicly registered fund with 1940 Act protections, available to a broader investor base than BUIDL’s qualified purchasers.

Compliance significance: Franklin Templeton’s choice to register BENJI as a 1940 Act fund — the same framework as conventional money market funds — represents a different compliance strategy from BlackRock’s Reg D approach. A 1940 Act fund requires SEC registration, ongoing disclosure, board oversight, and compliance with Rule 2a-7 (for money market funds). The cost is higher regulatory burden; the benefit is broader investor eligibility and the signal that tokenized funds can operate within the existing mutual fund framework.

Multi-chain deployment: Franklin Templeton’s expansion of BENJI to multiple blockchains raises novel compliance questions about which chain holds the authoritative register of record. Franklin Templeton maintains that the official shareholder record is held by its registered transfer agent, with the blockchain providing a supplementary but non-authoritative record. This position is legally necessary under 1940 Act requirements for registered investment companies.

Hamilton Lane — SCOPE and Tokenized Feeder Funds

Status: Deployed. Multiple tokenized feeder fund products operational since 2022.

Platform: Polygon (via Securitize), Figure (Provenance blockchain).

Products: Hamilton Lane has tokenized access to its flagship funds — Hamilton Lane Senior Credit Opportunities Fund, Equity Opportunities Fund — via feeder fund structures with lower minimum investments than direct fund access. The tokenized feeders reduce the typical $5M+ institutional minimum to $10,000-$20,000 ranges, targeting high-net-worth qualified purchasers via wealth management platforms.

Compliance significance: Hamilton Lane’s programme demonstrates that tokenization’s primary value proposition in private markets is not operational efficiency but distribution efficiency — reaching a larger investor base via digital wealth platforms without the administrative cost of processing thousands of small subscriptions manually. The compliance infrastructure (KYC/AML, subscription agreement execution, accredited investor verification) is moved earlier in the process and handled by the platform rather than the fund administrator.

Ares Management — Tokenized Credit Exposure

Status: Deployed (via tokenized products on multiple platforms).

Ares has enabled access to its credit strategies through tokenized feeder structures on multiple platforms including Securitize and Hamilton Lane’s SCOPE infrastructure. Ares represents the alternative credit manager segment that has moved most decisively into tokenized distribution.

Banks: Deployed

JPMorgan Chase — Kinexys (formerly Onyx)

Status: Deployed. Production operations since 2020; rebranded Kinexys 2024.

Platform: Proprietary permissioned blockchain (Quorum-derived, now Kinexys Digital Payments network).

Operations: Kinexys processes intraday repo transactions and cross-border FX payments for JPMorgan institutional clients. Daily volumes reached $2 billion+ in 2024. The system enables intraday settlement finality — a meaningful improvement over conventional correspondent banking timelines — and programmable conditional payments.

Token Collateral Network (TCN): JPMorgan conducted a $215 million pilot of tokenized BlackRock MMF shares as intraday repo collateral between JPMorgan and Goldman Sachs. This pilot validated the compliance architecture for using tokenized fund shares as regulated collateral — a precondition for the broader institutional DeFi market.

Compliance significance: Kinexys operates within a wholly permissioned environment with JPMorgan as the central operator. The compliance architecture is conventional correspondent banking compliance applied to a faster settlement rail. The more interesting compliance questions arise from TCN — where tokenized assets issued on public blockchains (BUIDL) are used as collateral in a JPMorgan-operated settlement network, creating a bridge between public and permissioned chains that requires compliance coverage on both sides.

Goldman Sachs — Goldman DAP (Digital Asset Platform)

Status: Deployed (institutional clients).

Platform: Proprietary permissioned blockchain; also operates on Canton Network.

Operations: Goldman Sachs has used its Digital Asset Platform for bond tokenization — including a €100 million digital bond for the European Investment Bank on the private blockchain — and for digital asset custody services for institutional clients. Goldman has been deliberate about not using public blockchains for client assets, citing client data privacy and regulatory risk management.

Canton Network: Goldman, along with several other major banks and asset managers, is a participant in the Canton Network — a privacy-preserving blockchain designed for institutional financial applications. Canton uses a synchronisation model that allows applications on private sub-ledgers to interoperate without exposing transaction data across participants.

HSBC — HSBC Orion

Status: Deployed (institutional clients).

Platform: Proprietary permissioned blockchain via HSBC Orion platform.

Operations: HSBC has used Orion for tokenized gold (HSBC Tokenised Gold — physical gold held in HSBC vaults, represented as digital tokens for institutional clients), digital green bonds, and structured product tokenization. HSBC Tokenised Gold is distributed to institutional and high-net-worth clients in Hong Kong.

Regulatory positioning: HSBC’s tokenization programme is built around its global custodian and securities services infrastructure, with tokenization layered on top of existing regulated custody frameworks rather than replacing them. This approach minimises regulatory novelty — the gold is held in regulated HSBC vaults, the custody framework is conventional HSBC custodian infrastructure — while adding DLT-native transferability.

Deutsche Bank — Taurus Partnership

Status: Deployed (custody infrastructure).

Platform: Taurus (Swiss DLT infrastructure provider), regulatory basis is DB’s German banking licence.

Operations: Deutsche Bank partnered with Taurus to provide digital asset custody for institutional clients via Deutsche Bank’s regulated custody infrastructure. The partnership enables Deutsche Bank clients to hold tokenized securities and crypto assets under Deutsche Bank’s regulated custody umbrella, with Taurus providing the DLT infrastructure layer.

Compliance significance: Deutsche Bank’s Taurus partnership is the model for how established custodians are entering digital asset custody — through partnership with DLT-native infrastructure providers rather than building proprietary chains, with the regulatory anchor remaining the bank’s existing securities custody licence.

BNY Mellon — Digital Asset Custody

Status: Deployed (live digital asset custody for institutional clients, October 2022 approval).

Platform: BNY Mellon proprietary platform, operating under New York DFS guidance.

Operations: BNY Mellon received approval from the New York Department of Financial Services (NYDFS) to provide Bitcoin and Ethereum custody for institutional clients in October 2022 — the first major US bank custodian to receive state-level approval. BNY has subsequently expanded its digital asset custody capabilities and is positioning as the institutional custodian of record for tokenized assets as the market develops.

SAB 121 / SAB 122 significance: BNY Mellon’s digital asset custody business was affected by SEC Staff Accounting Bulletin 121 (SAB 121), which required banks to record digital assets held in custody as balance sheet liabilities — a treatment that made digital asset custody economically costly for bank custodians. The reversal of SAB 121 by SAB 122 in January 2025 removed this balance sheet impediment, potentially accelerating bank custodian entry into digital asset custody at scale.

Broadridge Financial Solutions — DLT Repo (DLR)

Status: Deployed at scale. Crossed $1 trillion in cumulative notional repo on DLT.

Platform: Proprietary permissioned blockchain (DLR platform).

Operations: Broadridge’s DLT Repo platform enables intraday bilateral repo settlement among major broker-dealers and banks. The platform processes repo transactions on a DLT rail that provides settlement finality faster than conventional tri-party repo, enabling more efficient intraday collateral management.

Participating firms: Over 20 major financial institutions, including Goldman Sachs, HSBC, Société Générale, and others.

Compliance significance: The $1 trillion cumulative notional milestone validates DLT repo as a production-grade market infrastructure product, not a pilot. The compliance architecture is built around existing bilateral repo documentation (GMRA framework), with DLT providing the settlement and custody layer. Regulatory treatment follows conventional repo regulation; the DLT layer does not create novel regulatory obligations.

Emerging Institutional Participants: Piloting

State Street — Institutional Digital Asset Custody

State Street has announced digital asset custody capabilities in partnership with specialist providers and is engaged in multiple tokenization pilot programmes. Full operational deployment at scale is in progress.

Citi — Token Services

Citigroup launched Citi Token Services in 2023, piloting tokenized cash movements and trade finance applications. The programme tokenizes cash deposits (not crypto assets) to enable programmable, 24/7 payment settlement for corporate treasury clients. This “tokenized deposit” model is distinct from stablecoin models — the tokenized deposit is a Citi liability, not an independently issued token.

Standard Chartered — Libeara and Zodia Custody

Standard Chartered’s digital asset activities are conducted through Libeara (tokenized fund and bond platform, licensed in Singapore) and Zodia Custody (institutional crypto custodian, joint venture with Northern Trust). Libeara has tokenized Singapore government securities as part of Project Guardian.

Société Générale — Forge

SG-Forge is Société Générale’s digital asset subsidiary, operating under French regulatory frameworks. It issued the first covered bond (security) as a natively digital instrument on a public blockchain (Ethereum) for institutional settlement in 2019 and has continued to build digital asset infrastructure, including a euro-denominated stablecoin (EUR CoinVertible) for institutional use.

What the Institutional Pattern Reveals

The aggregate picture of institutional adoption patterns reveals four strategic choices that compliance teams should understand as they design their own programmes:

1. Public vs permissioned blockchain choice is a compliance choice, not only a technical one. BlackRock chose public Ethereum for BUIDL; JPMorgan chose permissioned Kinexys; Goldman chose Canton. Each choice has different compliance implications — public chains offer composability and secondary market depth but require whitelisting and transfer restriction mechanisms; permissioned chains offer access control but limit composability with the DeFi ecosystem.

2. Securitize is the dominant US compliance infrastructure provider. BlackRock, Hamilton Lane, Ares, and KKR have all used Securitize as their transfer agent and compliance layer. Securitize’s SEC registrations — as a broker-dealer and transfer agent — make it the natural choice for US Regulation D or 1940 Act tokenized fund structures. This concentration creates systemic compliance infrastructure risk: a material problem at Securitize would affect multiple major institutional tokenization programmes.

3. The compliance template exists. The combination of Regulation D / Reg S structure + SEC-registered transfer agent + smart contract transfer restrictions + qualified purchaser whitelist has been validated through BlackRock’s BUIDL, Hamilton Lane, and others. Compliance teams designing new programmes do not need to invent this template; they need to assess whether their specific programme can operate within it.

4. SAB 122 opens the bank custody floodgates. The reversal of SAB 121 removes the principal balance sheet impediment that made digital asset custody unattractive for bank custodians. Expect BNY Mellon, State Street, and JPMorgan to accelerate institutional digital asset custody capabilities through 2025-2026. This will deepen the regulated custody infrastructure available to tokenization programmes.

For related analysis, see /analysis/blackrock-changed-everything/ and /analysis/why-banks-are-tokenizing/.