Global Digital Finance (GDF) has announced findings from a working group report assessing the legal certainty and collateral mobility of Tokenised Money Market Funds (TMMFs) in Luxembourg, Ireland, and the UK. These jurisdictions are critical as Ireland and Luxembourg host over 80% of Europe’s MMFs. The working group included over 70 firms, such as JP Morgan, Blackrock, Lloyds Banking Group, and LSEG.
The report found relative legal certainty for TMMFs in Luxembourg due to existing statutory frameworks. The UK also demonstrated a low degree of legal uncertainty regarding the ownership and rights of digitally native TMMFs, with further clarity anticipated from the Property (Digital Assets etc.) Bill.
In contrast, Ireland currently lacks express statutory authority for tokenised shares. The report concluded that while Irish courts would likely treat TMMFs similarly to traditional shares by analogy, this certainty is not yet directly established in law. As part of the work, 30 firms also participated in the GDF Industry Sandbox, powered by Ownera, to prove the production use case for TMMF collateral mobility.
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