IMF Paper Probes Whether Deposit Tokens Could Flow Beyond Issuing Banks

A new International Monetary Fund (IMF) working note on tokenisation, authored by outgoing IMF Financial Counsellor Tobias Adrian alongside Yaiza Cabedo and Tommaso Mancini-Griffoli, now leading the BIS Innovation Hub, sets out a structured framework for how deposit tokens might be distributed and poses pointed questions to regulators about the boundaries of that distribution.

The paper maps three models of deposit token circulation. The current arrangement requires a direct relationship between the token holder and the issuing bank, which carries out know-your-customer (KYC) checks. A second model would route distribution through a wholesale intermediary, which passes tokens to individual wallets and takes on the KYC function, while the bank retains the liability. A third model involves a non-bank intermediary acquiring deposit tokens and issuing its own wrapped token backed by those instruments, with KYC performed at the wrapper level; under this construction the new tokens would not constitute a bank liability.

The authors note that the third model is technically feasible today, though no live implementations are known to exist. The distinction matters because it stretches the definition of what a deposit token actually is: once wrapped by a non-bank, the instrument’s regulatory character shifts materially. That shift is precisely the hard question the paper directs at regulators, making this a notable moment of intellectual framing from a multilateral institution rather than a rule or product announcement.