Tokenisation demands organisational change from investment managers

A NOTE from the International Monetary Fund in July 2026 observes that the current debate on tokenisation tends to focus on its impact on infrastructures and products.

Industry consensus appears to be that tokenisation’s benefits are faster settlement, the possibility of fractional ownership and potentially novel distribution channels.

Pilot transactions under Project Guardian, led by the Monetary Authority of Singapore, indicate that at least some of these benefits can be realised within the infrastructure of regulated market participants.

For investment management firms, however, the more consequential change tokenisation brings may lie elsewhere: in their organisational structures.

Tokenisation reshapes how money managers govern technology, service providers and, in particular, operational risk. This shift appears on two fronts.

First, fund units themselves can be tokenised; the register of investors is maintained on a distributed ledger and units can be subscribed, transferred and redeemed as digital tokens.

Second, funds increasingly hold tokenised or digital assets in their portfolios, from tokenised bonds to digital representations of money market instruments.

The immutable transaction history of public blockchains simplifies reconciliation and audit, but also creates a dependency on a system that investment managers neither own nor control. The net effect is a relocation of risk that existing organisational structures were not built for.

Regardless of the arrangement chosen, regulatory accountability remains with the investment manager.

In our view, four organisational changes should follow.

Continuous education must become part of the control framework

Many executives and their boards are highly experienced in traditional investment management, regulation and risk oversight. Tokenisation, however, introduces concepts that originate in technology.

Distributed ledgers, smart contracts, oracles, wallet infrastructure and blockchain-based settlement are not necessarily part of the current vocabulary.

Executives cannot effectively oversee risks they do not sufficiently understand, and employees cannot identify emerging vulnerabilities without the literacy to recognise them.

We propose targeted education that establishes a common baseline across the organisation. That does not mean turning every portfolio manager, risk manager and back-office team member into a blockchain engineer or cryptographer.

Senior management should understand the strategic implications of tokenisation. Risk and compliance functions need to know the associated control environment. Operational teams must be familiar with how digital asset processes differ from traditional fund infrastructure.

As regulators in Singapore and other leading jurisdictions sharpen their focus on operational resilience and technology risk, we see this tokenisation literacy as the starting point on which the remaining organisational changes can be built.

Due diligence must move beyond the traditional checklist

Investment managers as well as most due diligence service providers are used to assessing third-party service providers such as custodians, fund administrators, transfer agents and technology vendors via questionnaires.

Managing a tokenised fund adds new dependencies on blockchain infrastructure, digital-asset-specific custodians, smart-contract developers and tokenisation platforms.

Some are established financial institutions; others are novel actors in finance or even public goods (in the case of smart-contract platforms).

Beyond the current questions about financial strength, operational processes and regulatory licences, investment managers must now assess risks related to cryptography, smart-contract audit procedures, and the consequences of a failure of the underlying blockchain network.

Custody requires clearer allocation of control

Assets on a blockchain are moved with private keys – the digital credentials that authorise a transfer.

Investment management executives should know and have signed off on three things: who can initiate and approve transfers; how private keys are protected; and how access can be restored after loss, compromise or provider failure.

They must also understand which record proves ownership in their jurisdiction when an on-chain entry and an off-chain register diverge.

Under stress, these arrangements determine whether transactions can be executed or reconstructed, and whether investor rights remain enforceable.

Executives may delegate the operational execution. The oversight they cannot delegate. Boards need sufficient visibility to challenge a custody model, recovery arrangements and concentration risks on which their fund products depend.

Culture must keep pace

Organisational change of this kind does not end with training programmes and revised checklists.

Boards and their committees should place tokenisation on the regular agenda, define who is accountable for digital-asset risk, and establish reporting lines that allow them to govern the associated operating model.

In particular, they should be prepared to question novel digital asset providers with the same rigour they apply to fund administrators or technology firms. A culture in which such questions are routinely asked is itself a control.

Investment management firms that act now will be able to adopt tokenisation at scale and satisfy the supervisory expectations that are taking shape, in Singapore and beyond.

The technology is maturing. The harder work now lies inside the organisation.

Daniel Liebau is the founder of Singapore-based Lightbulb Capital, an innovation research and advisory firm focused on financial services. David Eckner is managing director of Opus Prime, the fund management company of the Chartered Investment Germany Group.