Every debate about digital assets eventually collapses into the same
framing: will central bank digital currencies win, or will private stablecoins?
I want to resist that question, because it points BRICS economies at the wrong
problem. The interesting issue in front of us is not which form of digital
money prevails. It is whether the different forms on offer, CBDCs, stablecoins,
tokenised bank deposits, can be made to work with each other across borders.
That problem is not primarily technical. It is legal and institutional, and as
a bloc BRICS is not yet organised to solve it.
Start by clearing up the taxonomy, because it changes what the argument
has to be about. A central bank digital currency is simply digital central-bank
money. A stablecoin is a privately issued digital claim whose credibility rests
on the quality of its reserves, its governance and the regulation around it. A
tokenised deposit is a third thing again: ordinary commercial-bank money
delivered through programmable infrastructure, which lets it become atomic,
machine-readable, and usable in smart-contract settlement. These are not three
competitors racing toward one winning technology. They are three layers of a
monetary system that could, in principle, coexist. The real question is whether
they can become interoperable forms of settlement rather than three separate,
closed ecosystems each optimising for itself.
The same clarity is missing from how we talk about regulation. The
instinct has been to regulate the technology, blockchain rails, tokens,
wallets, when the more useful instinct is to regulate the economic function
underneath it. If something performs a payment or settlement function, the
questions that matter are old and familiar: who bears the risk if it fails,
what backs the asset, can the holder redeem at par, who holds legal title to
the reserves, how are client assets protected, how does AML and KYC actually
work across the transaction. Technology moves globally and almost instantly.
Financial regulation remains stubbornly jurisdictional. That mismatch, not
block times or transaction throughput, is the structural problem cross-border
digital assets actually face.
My years building India's Open Network for Digital Commerce taught me a
lesson that generalises well beyond commerce: when you build an open network,
the mistake is trying to build the biggest marketplace on it. The value sits in
the protocol that lets many marketplaces, and many kinds of participant,
interact on common terms. Applied to digital assets, the prize is not the best
national CBDC or the most widely adopted stablecoin. It is the protocol layer
that lets different forms of digital money and different tokenised assets
interact across jurisdictions, without every pair of counterparties negotiating
a bespoke arrangement from scratch.
Here is where most of the current conversation goes astray. Putting an
asset on a blockchain is the easy part, and arguably the least consequential
part. The hard part is building the legal, regulatory and settlement
architecture around that asset so it holds up when the asset, the issuer, the
investor, the custodian and the secondary market sit in five different
jurisdictions. This is not hypothetical. Picture an asset originated in India,
tokenised by an issuer based in Singapore, bought by an investor in the UAE,
held by a custodian in Hong Kong, settled through a US-dollar stablecoin, and
eventually traded in a secondary market somewhere else again. Every one of
those legs raises a question that has nothing to do with cryptography: whose
law governs ownership, transfer, custody, insolvency, taxation, investor
protection and settlement finality. This is why I would argue legal
interoperability matters more, in the end, than technical interoperability.
That argument rests on treating governance as infrastructure in its own
right, not as a compliance afterthought bolted on to the technology. It is
tempting to think of infrastructure as the visible layer, the APIs, the
protocols, the databases, the blockchain itself. But the layer that actually
determines outcomes is governance: who is allowed to participate, who sets the
standards, who can change the protocol, how disputes get resolved, how
neutrality is maintained, how incentives are structured. We have spent two
decades getting reasonably good at making data interoperable. The next
challenge, a considerably harder one, is making rights and value interoperable.
A network that is technically open but institutionally captured, or
institutionally absent, will not earn the trust that financial infrastructure
requires. When the infrastructure in question carries property rights and
financial value rather than product listings, governance stops being a
nice-to-have and becomes the whole exercise.
None of this is an argument against tokenisation. It is an argument for
sequencing it correctly. Tokenisation can genuinely improve accessibility,
fractional ownership, distribution, transparency and settlement efficiency.
Moving settlement from T+2 to T+0 can meaningfully reduce settlement risk. But
multiply tokenisation platforms without a shared governance and legal layer
underneath them, and the result is platform fragmentation and liquidity
fragmentation instead of the promised efficiency gains. A tokenised illiquid
asset is still an illiquid asset unless there is an ecosystem of buyers,
sellers and interoperable venues around it. The danger ahead is not too little
tokenisation. It is tokenisation proceeding faster than the interoperability
layer that would let it function as an actual market rather than a collection
of walled gardens.
The stakes rise further as the technology matures, because we are not
simply digitising records anymore. The trajectory runs from digitising records,
to tokenising individual assets, to tokenising entire transactions, to
tokenising whole economic workflows: a tokenised security, a tokenised deposit,
a digital identity credential, a compliance credential and a smart contract all
interacting automatically to reach atomic settlement. At that point the system
looks less like crypto and more like new financial market infrastructure. Every
asset that can be tokenised can also be fractionalised, which is precisely why
the governance question cannot be left until later. The more the workflow
automates itself, the less room there is to fix a broken legal or governance
layer after the fact.
This also reframes what serious capital actually prices. Investors weigh
currency risk, counterparty risk, settlement risk, custody risk, liquidity
risk, regulatory risk, jurisdictional risk and technology risk together, not
settlement speed in isolation. Faster settlement does not automatically produce
better markets if it arrives bundled with fragmented liquidity and unclear
jurisdictional recourse. What institutional capital will actually reward is
legal certainty, regulated custody, clear accounting and tax treatment, and
enforceable interoperability, considerably more than it will reward a marginal
improvement in settlement time. Nor does tokenisation replace traditional
finance. Banks, exchanges, custodians, asset managers and market infrastructure
providers all remain relevant; what changes is their role, as they move from
being the entire transaction to being interoperable participants within it. The
winner in this transition is unlikely to be the ecosystem that eliminates
intermediaries. It is more likely to be the ecosystem that makes intermediaries
interoperable.
This is where BRICS has a genuine opening that the current national CBDC
conversations mostly miss. The instinct, understandably, is for each country to
build its own system: its own CBDC, its own regulatory sandbox, its own custody
rules. That instinct is not wrong on its own terms, monetary sovereignty is
worth protecting, but it is insufficient on its own, because a collection of
sovereign, non-interoperable systems produces exactly the fragmented outcome
tokenisation was supposed to fix. The more ambitious version of BRICS
digital-asset cooperation does not ask which member state builds the best CBDC.
It asks whether BRICS economies can agree on shared standards for identity and
KYC recognition, common frameworks for cross-border settlement finality, and
workable governance for resolving disputes when something goes wrong across
borders, all while every country keeps its monetary sovereignty fully intact.
National CBDCs and tokenised deposits stay domestic. Regulated private
stablecoins are free to coexist. Tokenised securities move across markets
because the underlying legal and compliance architecture recognises them
wherever they travel. No single country, and no single private platform,
controls the network.
That is digital public infrastructure thinking applied to international
finance rather than to domestic commerce, and it happens to play to a strength
several BRICS economies already have relative to most Western financial
centres. India, in particular, has already built and operationally proven open,
interoperable digital infrastructure at national scale for identity, payments
and commerce. That lived experience, more than any single country's crypto
regulation, is the raw material for a BRICS approach to digital assets worth
taking seriously.
The honest complication is that legal interoperability is far more
politically difficult to negotiate than technical interoperability. Getting
five or more sovereign regulators to agree on mutual recognition of custody,
insolvency treatment and settlement finality is a slower, more contested
process than agreeing on a messaging standard. But that is exactly why it is
the more valuable thing to get right, and exactly why the work should start
now, before each country's system hardens into an incompatible standard of its
own. The window in which BRICS can shape this jointly, rather than reconcile
five already-built systems after the fact, is not indefinite.
So the question worth putting to BRICS policymakers is not which country
will have the best CBDC or the most credible stablecoin regime. It is whether
the bloc is willing to do the harder, less visible work of building
interoperable governance and legal recognition across its members, before
technology forces a messier reconciliation later. We have become reasonably
good, as an industry and as regulators, at making data move across borders. The
next test, and the one that will actually determine whether tokenisation
changes finance or simply relabels it, is whether we can make rights and value
move across borders just as easily, without any one country or platform having
to surrender control to get there.
In this context, the idea of the Finternet gives us a useful,
consumer-centric framework for how this can evolve. The concept was proposed in
a 2024 paper by BIS General Manager Agustín Carstens and Nandan Nilekani,
following discussions at the G20 in Bengaluru, giving it a formal endorsement
from the institution that sits at the centre of global central-bank
cooperation. This has been since carried further through Networks for Humanity
(NFH), a global nonprofit Nandan helped build that connects people,
institutions and open networks around inclusive digital public infrastructure,
with the Finternet as its core mission for the future of finance. The Finternet
is not primarily about creating a new kind of money. It is about creating an
open, internet-like infrastructure for the movement and exchange of value,
where individuals and businesses, not financial intermediaries, sit at the
centre, able to transfer any financial asset, in any amount, at any time, to
anyone, anywhere. Carstens and Nilekani describe it as multiple financial
ecosystems connecting with each other much as the internet connects networks,
built on unified ledgers that make different forms of tokenised value
interoperable by design rather than by bilateral negotiation. It is, in other
words, the global equivalent of the DPI logic behind the argument above, aimed
one layer further out, at the end user rather than the institution.
"It would be unfortunate if we ended up with a fragmented system and legal framework in which different digital currencies don't interoperate." - Agustín Carstens, General Manager, Bank for International Settlements, "Legitimacy, Privacy, Integrity, Choice: Towards a legal framework for central bank digital currencies," BIS Innovation Hub–FSI conference, Basel, 27 September 2023






