Citi: Asset tokenization is globally ready but legal framework has not kept up.

Cross-border transactions using tokenized assets and currencies are now a reality, but the legal gap is hindering global expansion.

At the SmartCon 2025 conference in New York, leaders from Citi, DTCC, and Taurus stated that the technology is ready, but the laws between countries still lack uniformity, causing obstacles in the deployment process.

Ryan Rugg, Global Director of Digital Assets at Citi Treasury and Trade Solutions, stated that the Citi Token Services platform is operating in the US, UK, Hong Kong, and Singapore, handling billions of USD in actual transactions — from supply chain payments to capital markets payments.

However, the expansion into many other areas faces difficulties as Citi must obtain separate licenses in each country. The goal, according to Rugg, is to build a multi-bank, multi-asset financial network that operates seamlessly — “just like how email works today” — but regulations have not yet allowed for this.

Nadine Chakar, Global Head of Digital Assets at DTCC, stated that the recent “Great Collateral Experiment” has demonstrated that using tokenized assets — such as government bonds, equities, and money market funds — as collateral across time zones is feasible. However, the biggest barrier today is no longer technology, but market confidence and legal enforceability.

Chakar warns: “We talk about interoperability ( very easily, but in reality, it doesn't really work.”

Companies are currently using separate tokenization systems with different legal structures and smart contract designs. DTCC is collaborating with global payment organizations like SWIFT to develop a common set of standards, which do not necessarily require the use of the same technology but need a unified “language and protocol.”

Co-founder of Taurus, Lamine Brahimi, urged American institutions to learn from Switzerland, which has perfected the legal and technical framework for tokenized assets. He warned that without coordination, financial institutions would face the risks of fragmentation, security gaps, and high compliance costs.

Experts agree that the process of global tokenization will occur in stages: in the short term, the infrastructure of )wallet-based( will run parallel to traditional account systems; in the long term, digital wallets may become the new standard.

Although the infrastructure is ready, “the train will not be able to run if the legal framework does not keep pace,” Chakar said.