In this episode the guest, Sharon Lewis, Lead Partner for Future of Finance and Co-Chair of the Digital Asset & Blockchain practice at Hogan Lovells, talks about the landmark 2025 Global Digital Finance (GDF) Tokenized Money Market Fund Report.
This year-long initiative, co-authored by GDF, Hogan Lovells, Ownera and EY and supported by over 70 institutions including Barclays, BlackRock, Goldman Sachs, UBS, State Street and many others, combined in-depth legal analysis across the UK, Ireland and Luxembourg with real-world sandbox testing.
The 2022 UK LDI crisis highlighted the systemic risks of slow collateral mobility can create. This report shows a clear, legally robust path to solve it through tokenization – without requiring new primary legislation in the major European fund domiciles.
Key takeaways from the discussion:
• Tokenized money market funds (TMMFs) can already offer relative legal certainty as collateral in Luxembourg and Ireland under existing law; the recent UK Property (Digital Assets etc) Act 2025 has significantly reduced prior uncertainty in the UK.
• The report concludes that properly structured TMMFs can be issued, transferred, pledged under an English-law ISDA Credit Support Annex and withstand insolvency of the issuer – critical for institutional adoption.
• Sandbox testing successfully demonstrated instant settlement, automated margining, de-pegging events, default enforcement and tri-party funding, proving operational readiness today.
• Remaining priorities include regulatory guidance on title transfer and custody of digitally native fund units, plus updates to the UK Financial Collateral Arrangements Regulations to explicitly cover digital assets.
• Cross-border complexity remains the largest open item; standardised documentation and jurisdiction-by-jurisdiction legal opinions will be essential for scale.
Disclaimer
This material is for general entertainment purposes only, represents a personal opinion of the speakers, and is not intended to address the specific circumstances of any particular individual or entity, and does not constitute legal, tax, financial, investment, or any other form of professional advice. It is not intended to, and does not, give rise to any rights or obligations. No responsibility whatsoever (whether in contract, tort, negligence, statutory duty or otherwise) is accepted by the author, guest, or any affiliated entity for any loss, damage, cost or expense howsoever of any nature arising from its use, directly or indirectly from any reliance placed on this material or from any errors, inaccuracies, or omissions it may contain.
