Three Components on the Unified Ledger: The Tokenized Trilogy

Three Components on the Unified Ledger

Only two are money.

BIS Project Agorá maps out what a next-generation monetary system actually looks like. Three components. Different legal structures for each.

1. Tokenized Central Bank Money (Wholesale CBDC)

• Central bank liability. The ultimate settlement asset.
• 0% risk weight. Sovereign risk only. No credit risk.
• Central bank money on programmable infrastructure.
• Still money. Not a financial instrument. No netting rights beyond central bank frameworks.

2. Tokenized Commercial Bank Money (Tokenized Deposits)

• Bank liability. Deposit insurance applies.
• Group 1 assets under Basel IF same legal rights as deposits.
• Digitized bank deposit. Same legal structure. Same protections. Different technology.
• Still money. Still a claim on an issuer. But the issuer is a regulated bank.

3. Tokenized Assets (Securities, Bonds)

• Securities law applies. Not banking law.
• Group 1a cryptoassets under Basel IF classification conditions met.
• Risk-weighted by underlying exposure.
• USDM1 fits here: sovereign bond under New York law.

This is where netting CAN work. ISDA definitions apply. GMRA repos work. GMSLA lending works. UCC Article 8/9 perfected interests apply.

Why the Distinction Matters

Each component has different:

• Legal structure: Central bank liability, bank liability, or securities law
• Regulatory treatment: 0%, lower %, or risk-weighted by underlying
• Netting eligibility: Central bank frameworks, limited, or full ISDA/GMRA/GMSLA IF documented
• Collateral rights: None, deposit insurance, or perfected security interest

The BIS (2023) unified ledger concept brings all three together:

"Tokenised central bank money, tokenised commercial bank money, and tokenised assets can all coexist on a programmable platform."

But the legal foundations remain distinct. A claim on an issuer is not a financial instrument. Money doesn't net. Instruments do—but only with the right contract structure.

Institutional Traction

• 41 institutions in Project Agorá testing
• 7 central banks involved
• J.P. Morgan Kinexys processed $1.5T
• BlackRock BUIDL holds $2B+ AUM

The infrastructure is evolving. But the legal distinctions remain unchanged.

Key Takeaway

Three components. Two are money. One is financial instruments.

Legal structure first. Technology second. Contract structure third.

References

• BIS Annual Economic Report (2023) - Unified ledger concept and three building blocks
• BIS Angell Report (1989) - Four types of netting
• Basel Framework SCO60 - Prudential treatment of cryptoasset exposures
• OECD (2020) - Tokenised assets vs native tokens distinction
• GFMA (2025) - Institutional adoption data